expressly provided that “[t]he crimes within the jurisdiction of the Court shall not be subject to any statute of limitation” (supra para. 217). Likewise, recent international developments such as the establishment of the Extraordinary Chambers in the Courts of Cambodia and the Regulation on the Special Panels for East Timor expressly define crimes against humanity as crimes that have no statute of limitations. 264 265. According to the International Law Commission, “[a]t present, there appears to be no State with a law on crimes against humanity that also bars prosecution after a period of time has elapsed. Rather, numerous States have specifically legislated against any such limitation.” 265 Furthermore, even though neither the Convention against Torture nor the International Covenant on Civil and Political Rights expressly prohibit the application of the statute of limitations to grave violations of these treaties, the respective committees created to interpret and monitor compliance with the two treaties have established that torture and grave violations of the Covenant should not be subject to any statute of limitations. 266 266. In the regional sphere, the European Court of Human Rights has referred to the statute of limitations in cases of gross or massive violations of human rights. In this regard, it has indicated that, based on the seriousness of the crimes, the application of the statute of limitations is contrary to the obligation to ensure the right to life. 267 It has also recognized that even with the passage of time, the public interest in obtaining the prosecution and conviction of perpetrators was firmly recognized, in particular in the context of war crimes and crimes against humanity. 268 Cf. Parliament of the Kingdom of Cambodia. Law on the Establishment of the Extraordinary Chambers in the Courts of Cambodia for the Prosecution of Crimes Committed during the Period of Democratic Kampuchea, promulgated on August 10, 2001, with amendments adopted on October 27, 2004 (NS/RKM/1004/006), art. 5; United Nations Transitional Administration in East Timor. Regulation No. 2000/15 on the Establishment of Panels with Exclusive Jurisdiction over Serious Criminal Offences. UNTAET/REG/2000/15, June 6, 2000, art. 17.1. 264 265 UN. Report of the International Law Commission on the work of its sixty-ninth session (1 May-2 June and 3 July4 August 2017). A/72/10, p. 9, para. 45. Available at https://undocs.org/en/A/72/10, commentary 35 on Article 6 of the Draft articles on crimes against humanity, p. 71. 266 See, for example, Report of the Committee against Torture, Thirty-seventh session (6-24 November 2006) Thirtyeighth session (30 April-18 May 2007) (A/62/44), Chapter III, Consideration of reports by States Parties under Article 19 of the Convention: Mexico, para. 35, Concluding observation 16, and Italy, para. 40, Concluding observation 19; See also, for example, Report of the Human Rights Committee (Ninety-first session (15 October-2 November 2007) Ninety-second session (17 March-4 April 2008) Ninety-third session (7-25 July 2008) (A/63/40 (Vol. I)), Chapter IV, Consideration of reports submitted by States Parties under Article 40 of the Covenant and of country situations in the absence of a report resulting in public concluding observations, Panama (section A, para. 79, observation 7). 267 ECHR. Aslakhanova and Others. v. Russia, Nos. 2944/06 and 8300/07, 50184/07, 332/08, 42509/10, Judgment of December 18, 2012, para. 237: “Lastly, the application of the statute of limitations to the bulk of investigations of the abductions committed prior to 2007 has to be addressed. Bearing in mind the seriousness of the crimes, the large number of persons affected and the relevant legal standards applicable to such situations in modern-day democracies, the Court finds that the termination of pending investigations into abductions solely on the grounds that the timelimit has expired is contrary to the obligations under Article 2 of the Convention. The Court also notes that there is little ground to be overly prescriptive as regards the possibility of an obligation to investigate unlawful killings arising many years after the events, since the public interest in obtaining the prosecution and conviction of perpetrators is firmly recognised, particularly in the context of war crimes and crimes against humanity.” 268 ECHR. Aslakhanova et al. v. Russia, Nos. 2944/06 and 8300/07, 50184/07, 332/08, 42509/10, Judgment of December 18, 2012, para. 237, citing Brecknell v. The United Kingdom No. 32457/04, Judgment of November 27, 2007, para. 69. 67