109. In addition, both the right to access to justice and the right to judicial guarantees establish that one of the elements of due process is that tribunals reach a decision on cases submitted for their consideration within a reasonable time. Pursuant to that norm, the Commission will consider, in light of the specific circumstances of the case, the elements that the inter-American system has taken into account in its recent case-law, namely: (i) the complexity of the case; (ii) the procedural activity of the interested party; (iii) the conduct of the judicial authorities; and (iv)) the general effects on the legal situation of the person involved in the proceeding.135 The Inter-American Court has found that a prolonged delay may constitute, in itself, a violation of the right to a fair trial,136 and that, therefore, it is for the State to explain and prove why it has required more time than would be reasonable to deliver final judgment in a specific case.137 110. Finally, the Commission reiterates that "the inadmissibility of amnesty provisions, statutes of limitation, and grounds for excluding liability aimed at impeding the investigation and punishment of those responsible for serious human rights violations such as torture, summary, extralegal, or arbitrary executions, and forced disappearances, all of which are prohibited for violating non-derogable rights recognized by international human rights law."138 1. Due diligence in investigations of extrajudicial executions and forced disappearances 111. Regarding the extrajudicial executions of Silvia Reyes, Laura Raggio, and Diana Maidanik, the Commission points out that there is no record of the State having initiated ex officio investigations into their deaths on April 21, 1974, nor of it ordering even the minimum proceedings required in the event of a violent death at the hands of State agents, which were mentioned above. The only proceedings carried out and which appear in the file with the IACHR are certain statements by witnesses, a sketch, and photographs of the site taken more than 30 years later. There is no record of the State having taken other steps to throw light on the deaths of the alleged victims or to move the case forward in any way. 112. Likewise, with respect to the disappearances of Luis Eduardo González González in December 1974, and Oscar Tassino Asteazu in July 1977, there is no record of the State having initiated any ex officio investigation even though it is clear that it knew of both disappearances, due to the complaints and effort to find the alleged victims by family members in the days following their disappearances. The above is especially serious, given that, faced with a disappearance, the State's response is supposed to be prompt and effective to prevent grave human rights violations against the disappeared person. Likewise, the Commission underscores that there is no record of the State having made any effort to investigate or search for the alleged victims. 113. Finally, the Commission points out that in the case of both disappearances competence disputes arose between the ordinary justice system and the military courts, which took some two years to be resolved, even though it is clear that cases of crimes involving human rights violations cannot be heard by the military authorities. In the case of Luis Eduardo González González the dispute started on September 24, 1985 and was resolved on February 16, 1987. In the case of Oscar Tassino Asteazu,, the dispute over competence began on September 24, 1985 and was resolved on February 18, 1987 2. Enforcement of the Expiry Law 114. The Commission further notes that, in the three cases, after it was promulgated on December 22, 1986, the Expiry Law had the effect of preventing investigations into the facts, while attempting to ensure that they went unpunished. Following promulgation the alleged victims [Tr. next of kin of those who had died] brought IACHR. Report No. 111/10, Case 12.539, Merits, Sebastián Claus Furlan and family, Argentina, October 21, 2010, par. 100. I/A Court H.R., Case of the Santo Domingo Massacre v. Colombia. Preliminary Objections, Merits and Reparations. Judgment of November 30, 2012. Series C No. 259, par. 164. 136 I/A Court HR. Case of García Asto and Ramírez Rojas v. Peru. Judgment of November 25, 2005. Series C No. 137, par. 166; Case of Gómez Palomino v. Peru. Judgment of November 22, 2005. Series C No. 136, par. 85; Case of the Moiwana Community v. Suriname. Judgment of June 15, 2005. Series C No. 124, par. 160. 137I/A Court HR. Case of Ricardo Canese v. Paraguay. Judgment of August 31, 2004. Series C No. 111, par. 142; IACHR, Report No. 133/17, Case 12.332, Merits. Margarida Maria Alves and family members. Brazil. October 25, 2017, par. 105 138 I/A Court H.R., Case of Gelman v. Uruguay. Merits and Reparations. Judgment of 24, 2011. Series C No. 221, par. 225. 135 23