27 65. This characterization is consistent with other definitions included in different international instruments64 that similarly mention the following as concurring and constitutive elements of enforced disappearance: a) the deprivation of freedom; b) the direct intervention of State agents or their acquiescence; and c) the refusal to acknowledge the detention and reveal the fate or whereabouts of the affected person. 65 Additionally, the jurisprudence of the European Human Rights System66 and the decisions of different bodies of the United Nations67 and several Constitutional Courts and high national courts of the American States68 agree with the indicated characterization. 69                                                          64 Cf. Article 2 of the International Convention for the Protection of all Persons from Enforced Disappearance, U.N. Doc. A/RES/61/177, of December 20, 2006; Article 7, numeral 2, section i) of the Rome Statute of the International Criminal Court, U.N. Doc. A/CONF.183/9, of July 17, 1998, and The Working Group on Forced and Involuntary Disappearance of Persons, General Comment to Article 4 of the Declaration on the Protection of All Persons from Enforced Disappearance of January 15, 1996. Report to the Human Rights Commission. U.N. Doc. E/CN. 4/1996/38, para. 55. 65 Cf. Case of Gómez Palomino V. Perú. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 136, para. 97; Case of Chitay Nech et al., supra note 63, para. 85, and Case of Ibsen Cárdenas and Ibsen Peña, supra note 9, para. 60. 66 Cf. T.E.D.H., Case of Kurt v. Turkey, Application No. 15/1997/799/1002, Judgment of 25 May 1998, paras. 124 a 128; T.E.D.H., Case of Çakici v. Turkey, Application No. 23657/94, Judgment of 8 July 1999, paras. 104 a 106; T.E.D.H., Case of Timurtas v. Turkey, Application No. 23531/94, Judgment of 13 June 2000, paras. 102 a 105; T.E.D.H., Case of Tas v. Turkey, Application No. 24396/94, Judgment of 14 November 2000, paras. 84 a 87, and Case of Cyprus v. Turkey, Application No. 25781/94, Judgment of 10 May 2001, paras. 132 a 134 and 147 a 148. 67 Cf. H.R.C. Case of de Ivan Somers V. Hungría, Communication No. 566/1993, Report of July 23, 1996, para. 6.3; Case of de E. and A.K. V. Hungría, Communication No. 520/1992, Report of May 5, 1994, para. 6.4, and Case of de Solórzano V. Venezuela, Communication No. 156/1983, Report of March 26, 1986, para. 5.6. 68 Cf. Supreme Tribunal of Justice of the Bolivarian Republic of Venezuela, Case of Marco Antonio Monasterios Pérez, Judgment of August 10, 2007 (declaring the multioffensive and permanent nature of the crime of enforced disappearance); Supreme Court of Justice of Mexico, Thesis: P./J. 87/2004, “Enforced Disappearance of Persons. The period in which the statute of limitations begins to run is [when] the victim or their whereabouts appears” (affirming that the enforced disappearances are pemanent crimes and that the statute of limitations begins to run when the perpetration ceases); Criminal Chamber of the Supreme Court of Chile, Case of Caravana, Judgment of July 20, 1999; Plenary of he Supreme Court of Chile, Case of de desafuero de Pinochet, Judgment of August 8, 2000; Appeals Court of Santiago de Chile, Case of Sandoval, Judgment of January 4, 2004 (all declaring that the crime of enforced disappearance is continous, a crime against humanity, the statute of limitations does not apply, and it is not amnesty is available for it); Federal Chamber of Appeals on Criminal and Correctional Matters of Argentina, Case of Videla et al., Judgment of September 9, 1999 (declaring that enforced disappearance is a continous crime against humanity); Constitutional Tribunal of Bolivia, Case of José Carlos Trujillo, Judgment of November 12, 2001; Constitutional Tribunal of Peru, Case of Castillo Páez, Judgment of March 18, 2004 (declaring, because of that ordered by the Inter-American Court of Human Rights in the same case, that enforced disappearance is a permanent crime until the whereabouts of the victim are established). 69 Cf. Case of Goiburú, supra note 23, para. 83; Case of Chitay Nech et al., supra note 63, para. 85, and Case of Ibsen Cárdenas and Ibsen Peña, supra note 9, para. 60.