79 163. Furthermore, the Commission and the representatives claimed that in the new proceedings instituted against Urcesino Ramírez-Rojas there has been significant delay in the adoption of some evidentiary procedures, and although the criminal proceedings against him restarted on May 13, 2003, in August, 2005, at the time of presenting the closing arguments, that is, 27 months after restarting the criminal proceedings, they were still at the preliminary stage (supra paras. 145(l) and 146(e)). 164. More than fourteen years have passed since the detention of Urcesino RamírezRojas on July 27, 1991. The Court recognizes that during that term Urcesino RamírezRojas has remained deprived of freedom in several roles: as detainee, as defendant, and as convict. 165. In accordance with Article 202 of the Criminal Procedural Code in force at the time of instituting the new proceedings against the alleged victim, the investigation had to last four months, being it possible to extend such term for up to sixty additional days and, according to that same provision, in the case of complex proceedings, for up to eight additional non-extendable months. In the same way, Article 220 of the abovementioned procedural code, provided that the Superior Prosecutor could request an extension of the term only one time and always before the beginning of the oral proceedings. 166. As stated above, the Court considers that a long delay may per se constitute a violation of the principle of due process (supra para. 162). Notwithstanding the foregoing, in order to assess the reasonability of the second proceedings instituted against Urcesino Ramírez-Rojas according to the terms of Article 8(1) of the Convention, the Court takes three elements into account: a) the complexity of the matter, b) the procedural activity of the interested party, and c) the conduct of the judicial authorities.158 167. Based on the background presented in the chapter referring to Proven Facts, the Court recognizes that this is a complex case and that this must be taken into consideration to assess the reasonability of the term. The case file of Urcesino Ramírez-Rojas does not show that he took actions to delay the case. However, the Court remarks that at the time the closing arguments were presented in the instant case (supra para. 36), said investigation was still at its preliminary stage after twentyseven months of the beginning of the new process. 168. Furthermore, the Court remarks that the delay in the new criminal proceedings instituted against Urcesino Ramírez-Rojas analyzed herein was not a consequence of the complexity of the case, but of the systematically delayed proceedings on the part of the State authorities. In the instant case, the authorities in charge of the investigation requested an extension of the term for the preliminary proceedings several times (supra paras. 97(93) to 97(96), 97(98), 97(100), 97(104) to 97(106) and 97(108)). Although his criminal proceedings restarted on May 13, 2003, twentyseven months after they were still at the preliminary investigation stage. 158 Cf. Case of Acosta-Calderón, supra note 7, para. 105; Case of the Yakye Axa Indigenous Community, supra note 157, para. 65; and Case of the Moiwana Community, supra note 1, para. 160.