in which serious human rights violations were alleged.14From the foregoing, it is clear that, in the Court’s case-law, the inadmissibility of statutes of limitations has usually been declared based on the specificities of cases that involve serious human rights violations, such as forced disappearance of persons, extrajudicial executions and torture. In some of those cases, the human rights violations occurred in a context of massive and systematic violations. 20. As has been indicated by this Court, any human rights violation, by its very nature, implies a certain level of gravity, because it implies a breach of certain obligations by the State to respect and guarantee people’s rights and freedoms. However, this should not be confused with what the Court, throughout its case-law, has deemed to be “serious human rights violations,” which, as is evident from the aforementioned precedents, have their own connotation and consequences. To accept that this case involves a level of gravity for which the statute of limitations is inapplicable, would imply that in any case brought before the Court, involving human rights violations which of themselves imply gravity, such a procedure would be inappropriate.15 21. This Court recalls that in its Judgment in the instant case it did not declare the non-admissibility of the statute of limitations, but ordered the State to conduct a criminal investigation into specific conducts and establish the corresponding legal consequences, which did not rule out the possibility of a criminal action related to the facts under investigation being considered as prescribed. In view of the foregoing, and bearing in mind the Court’s constant case-law, in the instant case the Court deems it appropriate to close the procedure for monitoring compliance with the Judgment regarding the obligation to investigate the facts, as established in Operative Paragraph 9 of the Judgment. THEREFORE: THE INTER-AMERICAN COURT OF HUMAN RIGHTS, In exercise of its powers to monitor compliance with its decisions and pursuant to Articles 33, 62.1, 62.3, 65, 67 and 68.1 of the American Convention on Human Rights, Articles 25.1 and 30 of its Statute and 31.2 and 69 of its Rules of Procedure, DECLARES THAT: 14 Cf. Case of Gelman v. Uruguay. Merits, Reparations and Costs. Judgment of the Inter-American Court of February 24, 2011. Series C No. 221, para. 225; Case of Contreras et al. v. El Salvador. Merits, Reparations and Costs. Judgment of the Inter-American Court of August 31, 2011. Series C No. 232, para. 185 (d), and Case of González Medina and relatives v. Dominican Republic. Preliminary Objections, Merits, Reparations and Costs. Judgment the Inter-American Court of February 27, 2012. Series C No. 240, para. 185 (e). 15 Cf. Vera Vera et al. supra note 10, para.118. 7

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