113. In the case of Cárdenas and Ibsen Peña v. Bolivia, that criterion is reiterated when it is established that " in certain circumstances, international law considers statutes of limitations to be inadmissible and inapplicable[,] along with amnesty laws and exemptions from liability, so as to maintain the State’s punitive power in effect for actions which, because of their seriousness, must be stopped and also to avoid their repetition."147 114. Subsequently, in the cases of Gomes Lund et al. ("Guerrilha do Araguaia") v. Brazil and Gelman v. Uruguay, regarding grave human rights violations committed under military dictatorships, the Court reiterates its jurisprudence that "[...] the statute of limitation provisions [...] intended to prevent the investigation and punishment of those responsible for serious violations to human rights such as torture, summary, extrajudicial, or arbitrary executions, and enforced disappearance are not admissible, all of which are prohibited for contravening irrevocable rights recognized by International Law of Human Rights."148 115. This position on the prohibition of prescription in criminal cases involving grave human rights violations has also been maintained by the Court in cases in which said violations occurred within the framework of internal armed conflicts.149 4. Considerations regarding the prescription of judicial actions brought to obtain reparation for certain human rights violations 116. The Commission notes that there have been major developments on this topic in both international and comparative law. 117. With regard to the victims of forced disappearance -- as is the case of three of the matters examined in this report -- the Working Group on Enforced or Involuntary Disappearances pointed out already in 1989, in its General Comments on Article 19 of the Declaration on the Protection of All Persons from Enforced Disappearance that " civil claims for compensation shall not be [...] made subject to statutes of limitation. 150 118. In line with that and without restricting it to cases of forced disappearance, the then U.N. Special Rapporteur on the Right to Restitution, Compensation and Rehabilitation for Victims of Gross Violations of Human Rights and Fundamental Freedoms, Theo van Boven pointed out that: (...) the application of statutory limitations often deprives victims of gross violations of human rights of the reparations that are due to them. The principle should prevail that claims relating to reparations for gross violations of human rights shall not be subject to a statute of limitations. In this connection, it should be taken into account that the effects of gross violations of human rights are linked to the most serious crimes to which, according to authoritative legal opinion, statutory limitations shall not apply. Moreover, it is well established that for many victims of gross violations of human rights, the passage of time has no attenuating effect; on the contrary, there is an increase in 147 I/A Court HR. Case of Ibsen Cárdenas and Ibsen Peña v. Bolivia. Merits, Reparations and Costs. Judgment of September 1, 2010, Series C No. 217, par. 207. 148 I/A Court HR. Case of Gomes Lund et al. ("Guerrilha do Araguaia") v. Brazil. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 24, 2010. Series C No. 219, par. 171; and I/A Court H.R., Case of Gelman v. Uruguay. Merits and Reparations. Judgment of February 24, 2011. Series C No. 221, par. 225. 149 See, for example, I/A Court HR. Case of the Massacres of El Mozote and Nearby Places v. El Salvador. Merits, Reparations and Costs. Judgment of October 25, 2012, Series C No. 252, par. par. 283. 150 Working Group on Enforced or Involuntary Disappearances, General Comments on Article 19 of the Declaration on the Protection of All Persons from Enforced Disappearance, E/CN.4/1998/43, para. 73. 23