102. Finally, regarding the conclusion of the criminal trial, the Court deems it appropriate to recall that on May 8, 2006, the Court of Justice of Pará terminated M.C.N.'s criminal liability by reason of the statute of limitations, declaring it expired due to the 17 years that had passed between the admission of the Public Prosecutor's Office’s initial accusation and the “pronúncia” ruling. 174 Thus, over 23 years after the death of Gabriel Sales Pimenta, the trial was closed without having clarified the circumstances of his death or identified or prosecuted those responsible. 103. As shown in the evidence found in the case file, the slow and negligent actions of the judicial authorities contributed significantly to the expiration of the statute of limitations. For example, given the existence of sufficient circumstantial evidence of responsibility for the crime as well as evidence of a deliberate crime against life, there was no justification for the delay in issuing the “pronúncia” judgment (a year and eight months from the date of recognition of the Court's jurisdiction), which was not even a sentence but merely a decision to continue the trial before the Jury Court. 175 As the expert witness Dissenha noted, the extreme delay in issuing the “pronúncia” judgment was decisive for the case exceeding the statute of limitations, as it was precisely due to the time elapsed between the admission of the Public Prosecutor's Office’s initial accusation and the “pronúncia” judgment (17 years) that the statute of limitations was applied in favor of the defendant M.C.N. Another factor the Court sees as contributing to the application of the statute of limitations is the authorities’ failure to take concrete, efficient measures to ensure the defendant's appearance during the trial, which caused a series of delays in the proceedings. 176 104. The Court therefore finds that the application of the statute of limitations in this case, and the resulting final closing of the case, were not the result of normal, expeditious criminal proceedings, but by a series of state actions and omissions during the course of those proceedings. 177 105. The Court therefore concludes that the State did not fulfill its obligation to act with enhanced due diligence to investigate earnestly and thoroughly the death of human rights defender Gabriel Sales Pimenta. b.2 Reasonable timeframe 106. The Court has stated that the right of access to justice in cases of human rights violations must ensure, within a reasonable time, the right of the alleged victims or their family members to 174 The expert witness Dissenha clarified that according to rules of the statute of limitations, the crime in question would exceed the statute of limitations in ten years, after taking into account the age of M.C.N. at the time of the “pronúncia” judgment, and that the admission of the Public Prosecutor's Office’s initial accusation and the “pronúncia” ruling constitute two interruptions of the statute of limitations under Article 117 of the Brazilian Criminal Code. Cf. Expert opinion of Rui Carlo Dissenha during the public hearing of this case. 175 As the expert witness Dissenha noted, this delay in particular was key to the lapse under the statute of limitations and “if the judgment of accusation had been issued a few years earlier, the statute of limitations would not have applied.” Written version of Rui Carlo Dissenha’s expert opinion from March 11, 2022 (evidence file, folio 6633). 176 Furthermore, as the expert witness Dissenha stressed during the hearing, until the year 1996, the Brazilian Code of Criminal Procedure established that the trial must continue in the absence of a defendant summoned to any procedural step who failed to appear without justification. Cf. Article 366 of the Code of Criminal Procedure until modified by Law 9.271 of April 17, 1996. This means that after procedural steps at which M.C.N. failed to appear without justification, the trial should have continued despite his failure to appear. Moreover, until 1996, the statute of limitations could not be suspended while a defendant was a fugitive. The expert witness Dissenha declared that the statute of limitations expiration in this criminal trial was “constructed,” not from one isolated act but as a consequence of a series of egregious acts and omissions on the part of state officials over the course of years. Cf. Expert opinion by Rui Carlo Dissenha provided at a hearing on March 22, 2022. Similarly, the expert witness Kalil stated that “a lapse under the statute of limitations in criminal matters ends the punitive claim due to the passage of time, and it generally limits the punitive power of the State to prosecute unlawful conduct and punish those who commit it. It is a guarantee that all judges must observe for every criminal defendant. However, when that lapse is caused by the State’s failure to take measures it should have taken through the judiciary [...] when it had the power to prevent that lapse but did nothing, and the context is one of general violence as well as intimidation of those defending the rights of people along with those who are asserting their rights [...] I do not think the statute of limitations [...] was intended for this; it should not be used as a mechanism for perpetuating impunity.” Expert opinion by Renan Kalil provided at a hearing on March 23, 2022. 177 30