violation of the Convention that adds to the original violations thereof in this case. Self-amnesty, in and of itself, violates, by its very existence, Articles 1(1) and 2 of the American Convention, hinders access to justice by the victims or their next of kin (Articles 25 and 8 of the Convention), obstructs the investigation of the facts (required by Article 1(1) of the Convention), prevents the administration of justice and the granting of appropriate reparations. They entail, in sum, the most flagrant obstruction and denial of justice, leaving the victims and their next of kin utterly and completely defenseless. 18. Such denial of justice is accompanied by aggravating circumstances, with their ensuing legal consequences, insofar as it implies a deliberate cover-up of violations of fundamental rights through a systematic pattern of illegal or arbitrary detention, kidnapping, torture, and forced disappearance of persons, which are absolutely prohibited under jus cogens.15 Consequently, the aforesaid self-amnesties bring upon the State aggravated international liability. 19. Said aggravated international liability is the result of violating jus cogens, giving rise to an objective illegality,16- which entails other consequences in relation to reparations. No State may resort to contrivances in order to violate jus cogens norms;17 its prohibitions are not dependent on the State’s acquiescence. 18 In its most recent Judgment rendered four days ago, in the Case of Goiburú et al. v. Paraguay (on September 22, 2006), the Inter-American Court extended the material scope of jus cogens to include the right of access to justice at the domestic and international level, in the sense I have been advocating in this Court for a long time now, as I pointed out in my Separate Opinion (paras. 62-68) in the aforesaid case. 20. Furthermore, said denial of justice constitutes a gross violation of Articles 1(1), 2, 25 and 8 of the American Convention. The State that commits such a violation by way of a “self-amnesty” fails to “respect” and “ensure respect for” the rights enshrined in the American Convention (in accordance with the general obligation contained in Article 1(1) thereof); fails to harmonize its domestic law with the American Convention (in accordance with the general obligation contained in Article 2 thereof), and hinders access to justice, not only formally but also materially19 (Articles 25 and 8 of the Convention). That is to say, access to justice and due process of law as a whole are affected, denied by “self-amnesty.” The inextricable interrelationship between the provisions of Articles 25 and 8 of the American Convention, violated in this case, is emphatically recognized by the most 15 . A. O'Shea, op. cit. supra n. (2), p. 186, and cf. pp. 198-199, 219 and 222-223. 16 . Cf. A. Orakhelashvili, “Peremptory Norms and Reparation for Internationally Wrongful Acts,” 3 Baltic Yearbook of International Law (2003) p. 26. 17 . Cf. B. Chigara, op. cit. supra n. (9), pp. 151 and 164, and cf. pp. 26, 35-36, 60 and 91. 18 . Precisely to avoid that the State resorts to subterfuge in order to cover up crimes, in recent years, the erosion of the traditional connection between territoriality and nationality has been promoted for the purpose of “denationalizing” the administration of criminal justice in certain circumstances and protecting the legitimate interests of the international community in this area; cf. L. Reydams, Universal Jurisdiction - International and Municipal Legal Perspectives, Oxford, University Press, 2004, pp. 27 and 220-221. And cf. also Beigbeder, Judging Criminal Leaders - The Slow Erosion of Impunity, The Hague, Nijhoff, 2002, pp. 14 and 207-214. 19 . Cf. A. O'Shea, op. cit. supra n. (2), pp. 270-272, and cf. p. 273.