19 international standards, especially the precepts included in the American convention, cannot be considered valid and, as stated by [the Inter-American Court], it is neither admissible or appropriate to resort ‘to amnesty, pardon, prescription periods, or create measures to exclude responsibility.”34 d) Additionally, in the case of 19 Tradesmen v. Colombia, the Criminal Appeals Chamber of the Supreme Court of Justice of Colombia issued a decision regarding an appeal for review initiated by a Criminal Judicial Prosecutor, in which it decided to declare the invalidity of the actions of the military criminal justice and the decision to cease the proceeding, as well as to forward said process to the civil criminal jurisdiction (National Human Rights Unit and International Humanitarian Law) so it would continue with the investigations.35 The request made by the Judicial Prosecutor and the Supreme Court were based on the provisions of the Judgment issued by the InterAmerican Court. As proven by the application of international law in domestic law, it is not essential to specify the measures that must be adopted by the different public authorities called upon in order to eliminate the obstacles that prevent compliance with the obligation to investigate. There is the possibility that in some cases the Tribunal has issued very specific orders, as mentioned by the Constitutionality Court regarding the case of Raxcacó Reyes v. Guatemala; however, the Tribunal need not adopt such detailed decisions. This Tribunal assumes that the State’s good faith with regard to compliance with the obligations it has agreed to, and its commitment as a Party to the American Convention, guarantee subjection to the orders of those Judgments affecting Guatemala and the Court’s jurisprudence that interprets and applies the rights contained in said treaty. 39. Conclusion of the Court Based on all the aforementioned, it is clear that the decisions adopted by domestic authorities, especially prosecutors and judges, who are able to adequately and diligently promote the investigation in the present case, constitute a form of compliance with the Court’s orders 40. 34 Criminal Appeals Chamber of the Supreme Court of Justice of Colombia, Judgment of September 17, 2008 (Appeal for Review). 35 Cf. Case of 19 Tradesmen v. Colombia. Monitoring Compliance with Judgment. Order of the President of the Inter-American Court of Human Rights of November 26, 2008, Considering Clause four.

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