international commitments on gender equality and the rights of women.”274 It also emphasized, institutionally, the creation in 2005 of the National Institute of Women with “the commitment to promote policies of gender equality,” as well as the creation of specialized courts in the matter. It also affirmed that “there has been sustained progress on the normative plane.”275 E.1.1 Non-applicability of exclusionary factors of criminal responsibility 246. The Court recalls that, in deciding the Gelman case, it determined that “the Expiry Law lacks effectiveness due to its incompatibility with the American Convention and the Inter-American Convention on Forced Disappearance of Persons, inasmuch as it can impede the investigation and eventual punishment of those responsible for serious violations of human rights.” It, therefore, ordered that “the State must ensure that [such law] does not again represent an obstacle […] for the identification and, if appropriate, the punishment of those responsible of […] serious violations of human rights […] in Uruguay.” 247. In monitoring compliance of that case, the Court noted that Uruguay had adopted Decree 323 of June 30, 2011 and Law 18,831 of October 27, 2011, the latter of which in its Article 1 deprived the Expiry Law of effectiveness. It pointed out that these measures were “concrete steps directed to compliance of the ordered reparation” and that the Court considered “that the enacting of those norms are a partial compliance with this measure of reparation.”276 The Court, however, stated that it could not “assess the total compliance of the measure” ordered because “there persist judicial interpretations that represent an obstacle to the investigation of serious violations of human rights committed during the dictatorship.” It especially referred to the judicial interpretations that held unconstitutional Articles 2 and 3 of Law 18,831, which referred to the non-applicability of the statute of limitations and the nature of the crimes against humanity that occurred during the dictatorship, but that do not recognize the nonapplicability of the statute of limitations of such serious human rights violations. 277 Uruguay expressly mentioned “the Convention on the Political Rights of Women of 1948, the Convention on the Elimination of all Forms of Discrimination against Women of 1979 and the Convention to Prevent, Sanction and Eradicate Violence against Women of 1994.” 274 It mentioned as “an example,” the law on sexual and reproductive health of 2009, the law on sexual harassment of 2009, the law on gender identity of 2009; the law on the voluntary interruption of pregnancy of 2012 and the Law on Violence against Women based on Gender (Law 19,580), of December 22, 2017, which created “Specialized Courts,” as well as “the incorporation of gender into educational, health, work and security policies, as well as those for older adults.” The State also underscored that it had incorporated, in the criminal area, “feminicide as murder in the first degree in those cases in which a woman is murdered for reasons related to her gender.” It also indicated that, in 2020, it published a “guide for the judiciary on stereotypes of gender and the international standards on women’s rights.” The State also pointed out that “the Budgetary Law 19,924 of [2020] created in each ministry a specialized unit” for issues of gender. 275 Case of Gelman v. Uruguay. Monitoring compliance of judgment. Order of the Inter-American Court of November 19, 2020, considering paragraph 28. 276 Case of Gelman v. Uruguay. Monitoring compliance of judgment. Order of the Inter-American Court of November 19, 2020, considering paragraph 30. The Court notes that the State remitted, as a “new fact,” in this case, a decision of the Court of Flores, of December 14, 2020, that, as the State itself indicated, “encompasses both the principle of statutory limitations and the classification of crimes against humanity for facts initially included in the so-called “Expiry Law” (evidence file, f. 7656). Without evaluating this decision, the Court considers that it does not contradict the affirmations of the witness Perciballe and the expert Chargoñia, referred to in a following paragraph. 277 64