servants who enjoy the constitutional privilege to a preliminary hearing on the merits. The petitioners pointed out that the same decision launched a judicial investigation to bring the pensions on a par with the salaries of active employees and to compute the amount of the compensatory payments for increases that were never perceived.3 28. The petitioners indicated that on April 7, 2003, the expert submitted his report which was then challenged by SUNAT, in a written document, on April 23, 2003, which, SUNAT said, was not intended to attack the investigation but to question the content of the judgment being enforced. 29. The petitioners pointed out that the Sixty-sixth Civil Court in Lima, issued Resolution No. 80 which: i) found that SUNAT’s challenge of the expert report was groundless; ii) ordered the approval of the expert report; iii) ordered SUNAT to pay the pensions brought on a par with the salaries of active employees, on the third day after it had been notified; and iv) ordered SUNAT to pay the increases the members of the association had never received up to the date of compliance with the previous point. 30. Despite this resolution, the petitioners added, SUNAT refused to comply with the judgment and lodged an appeal challenging the ruling of the Sixty-six Civil Court in Lima. In decisions dated May 5, 2005, and May 8, 2006, the first expert report was rejected in both first and second instance, and the criteria in which to base a new expert report were established. According to the petitioners, the new expert accountant followed the criteria to the letter. 31. Nevertheless, the petitioners said, SUNAT continued to obstruct and delay complying with the terms of the judgment, submitting observations and lodging challenges to this second expert report. The petitioners added that on July 24, 2006, the Sixth Civil Chamber of the Lima Superior Court ruled the second expert report null and ordered a third expert report aimed at excluding the remuneration of active service employees, even though it was precisely that exclusion that was ruled inapplicable in the amparo decision which sided with the petitioners. The petitioners alleged that the purpose of these decisions was to eliminate any impact the Supreme Court of Justice ruling of October 25, 1993 may have. In that regard, the petitioners emphasized 3 The annexes submitted by the petitioners indicate that these decisions were adopted by different rulings of the same court. The first, on September 23, 2002, ordered an expert accounting report, and the second, on September 25, 2002, directing the Public Ministry to intervene due to the repeated refusals to enforce the judgment. 14