24 against humanity. Therefore, they are overtly incompatible with the wording and the spirit of the American Convention, and undoubtedly affect rights embodied in such Convention. This constitutes in and of itself a violation of the Convention and generates international liability for the State.” 86 When laws of this type were enacted in countries like Argentina and Uruguay, the Commission wrote that those States had failed in their obligation to ensure the right of access to justice, thereby violating the rights protected under Articles 8(1), 25(1) and 1(1) of the American Convention. 87 83. The Commission has highlighted that Decree-Law No. 2191, known as the “selfamnesty” law in Chile, is incompatible with Articles 8(1), 25(1), 1(1) and 2 of the American Convention. 88 Specifically, the Commission has affirmed that: (…) the application of amnesty laws, which bar access to justice in cases concerning serious human rights violations, render ineffective the obligation of the States Parties to respect the rights and freedoms recognized in the Convention and to ensure their free and full exercise by all persons subject to their jurisdiction, without discrimination of any kind, as established in Article 1(1) of the Convention. Such laws therefore eliminate the most effective means of enforcement of human rights, that is, the adjudication and punishment of those responsible. 89 84. With respect to the compatibility of Decree Law 2191 with the American Convention and the State’s duty to adapt its domestic legal system to the provisions of the American Convention in order to ensure the exercise of the human rights protected therein, the Inter-American Court has held that: Pursuant to Article 2 of the Convention, such adaptation implies the adoption of measures following two main guidelines, to wit: i) the annulment of laws and practices of any kind whatsoever that may imply the violation of the rights protected by the Convention, and ii) the passing of laws and the development of practices tending to achieve an effective observance of such guarantees. 90 It is necessary to reaffirm that the duty stated in i) is only complied when such reform is effectively made. 91 international human rights law.” I/A Court H.R., Case of Almonacid Arellano et al. v. Chile. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 26, 2006. Series C No. 154, para. 112, citing I/A Court H.R., Case of Barrios Altos v. Peru. Merits. Judgment of March 14, 2001. Series C No. 75, para. 41. 86 I/A Court H.R., Case of Almonacid Arellano et al. v. Chile. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 26, 2006. Series C No. 154, para. 119, I/A Court H.R., Case of Barrios Altos v. Peru. Interpretation of the Judgment on the Merits (Art. 67 American Convention on Human Rights). Judgment of September 3, 2001. Series C No. 83, para. 18. 87 See IACHR, Report No. 28/92, Cases 10.147, 10.181, 10.240, 10.262, 10.309 y 10.311, Argentina, October 2, 1992, paragraphs 37, 39 and 41; and IACHR, Report No. 29/92, Cases 10.029, 10.036, 10.145, 10.305, 10.372, 10.373, 10.374 and 10.375, Uruguay, October 2,1992, paragraphs 45, 46, 49 and 51. 88 IACHR, Report No. 34/96, Cases 11.228, 11.229, 11.231 y 11282, Chile, October 15, 1996, paragraphs 104 and 107. 89 IACHR, Report No.133/99, Case No. 11.725, Carmelo Soria Espinoza, Chile, November 19, 1999, para. 66, citing two earlier Commission cases, namely: IACHR, Reports 28/92 (Argentina) and 29/92 (Uruguay). See also the following reports that deal with Chile’s Decree Law 2191: IACHR, Report No. 25/98, Cases 11.505 and others, Chile, April 7, 1998, and IACHR, Report No. 34/96, Cases 11.229 and others, Chile, October 15, 1996. 90 I/A Court H.R., Case of Ximenes Lopes v. Brazil. Merits, Reparations and Costs. Judgment of July 4, 2006. Series C No. 149, para. 83; I/A Court H.R., Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 136, para. 91; y I/A Court H.R., Case of the “Mapiripán Massacre” v. Colombia. Merits, Reparations and Costs. Judgment of September 15, 2005. Series C No. 134, para. 109. 91 I/A Court H.R., Case of Raxcacó Reyes v. Guatemala. Merits, Reparations and Costs. Judgment of September 15, 2005. Series C No. 133, para. 87; I/A Court H.R., Case of the Yakye Axa Indigenous Community v. Paraguay. Merits, Reparations and Costs. Judgment of June 17, 2005. Series C No. 125, para. 100; and I/A Court H.R., Case of Caesar v. Trinidad and Tobago. Merits, Reparations and Costs. Judgment of March 11, 2005. Series C No. 123, paragraphs 91 and 93.”