20 considered necessary for the proper trial of the case, which constitutes a violation of Article 8(1) of the Convention (supra 68). 77. Article 8(1) of the Convention also refers to reasonable time. This is not an easy concept to define. In defining it, one may invoke the points raised of the European Court of Human Rights in various decisions in which this concept was analyzed, this article of the American Convention being equivalent in principle to Article 6 of the European Convention for the Protection of Human Rights and Fundamental Freedoms. According to the European Court, three points must be taken into account in determining a reasonable time within which the trial must be conducted: a) the complexity of the matter; b) the judicial activity of the interested party; and c) the behavior of the judicial authorities (See, inter alia, Eur. Court H.R., Motta judgment of 19 February 1991, Series A no. 195-A, para. 30; Eur. Court H.R., Ruiz-Mateos case v. Spain judgment of 23 June 1993, Series A no. 262, para. 30). 78. With regard to the first point, it is clear that the matter under consideration is somewhat complex, since the investigations were very extensive and the evidence copious, owing to the wide impact of the death of young Genie-Lacayo (supra 69). All of this could justify the fact that the trial, which also involved many incidents and instances, lasted longer than others with different characteristics. 79. As regards the second point, which refers to the procedural activity of the interested party, there is no record that Mr. Raymond Genie-Peñalba, the victim's father, behaved in a manner incompatible with his role as private accuser or that he obstructed the process, because he did no more than apply the impugnment measures recognized in the legislation (supra 70). 80. With reference to the third point, that is, the behavior of the Nicaraguan judicial authorities, this Court finds that there were no excessive delays at the various stages of the proceedings, with the exception of the phase which is yet to be settled (supra 71), that is, the application for judicial review before the Supreme Court of Justice filed by the accusing party on August 29, 1994, admitted by that Tribunal on August 31 and which, notwithstanding the various requests from the parties, has still not been disposed of. Even considering the complexity of the case, as well as the excuses, impediments and substitution of judges of the Supreme Court of Justice, the two years that have elapsed since the application for judicial review was admitted is not reasonable; this Tribunal therefore deems it to violate Article 8(1) of the Convention. It will do so in the operative part relating to Article 1(1), which contains the general obligation to respect the Convention. 81. In addition to the examination of possible delays at the various stages of the proceeding, in determining what constitutes a reasonable time throughout the entire process, the European Court has employed what it refers to as a "global analysis of the proceeding" (Motta, supra 77, para. 24; Eur. Court H.R., Vernillo judgment of 20 February 1991, Series A no. 198 and Eur. Court H.R., Unión Alimentaria Sanders SA judgment of 7 July 1989, Series A, no. 157). Even without taking into account the police investigation and the time spent by the Office of the Attorney-General of the Republic of Nicaragua in bringing the case before the court of first instance, that is, between July 23, 1991, on which date the court issued the order to initiate the proceeding, and the present time at which a firm judgment has still not been rendered, more than five years have elapsed; the Court deems this period to exceed the limits of reasonableness prescribed in Article 8(1) of the Convention. 82. Faced with the arguments adduced by the Commission and the Government