violations, the State must ensure that it never again becomes an impediment to investigate the facts at hand.”231 205. It should be recalled that the Court has already noted in its March 20, 2013 Order of monitoring compliance of judgment in the Gelman case that, in the first place, “it is inadmissible to consider the statute of limitations with respect to the prosecution of crimes, which may be continued to be committed over time, such as the crime of forced disappearance. Being a crime of a permanent nature, the admissibility of the principle of non-retroactivity of criminal law or of statutory limits is not in dispute.”232 206. Secondly, with respect to both the act of forced disappearance as well as other serious violations of human rights, such as extrajudicial executions, the Court stated that “it is incompatible with the international obligations of a State Party to the Convention to cease investigating, prosecuting and, where appropriate, punishing those responsible for gross violations of human rights which, by their nature, are not subject to the statute of limitations, and which impair the victims’ right to have access to justice and maintain a situation of impunity which the State’s own authorities and organs have fostered….”233 207. The Court added that, “in cases where the State apparatus has served as an instrument for the commission of these serious crimes and where the State agents who committed them have been assured the tolerance, support, at the time of their commission, with the tolerance, support and guarantees of impunity by the State itself,” there can be no strict interpretation of the procedural guarantees of statutory limitations without this implying “a distortion of their very meaning and failing to meet the victims’ legitimate expectations to their right to access to justice.”234 208. The State must conduct the investigations ordered in this judgment in accordance with the above-mentioned guidelines. 209. It must also conduct those investigations effectively so that they are done speedily and within a reasonable time by implementing the appropriate measures,235 including the avoidance and, pursuant to the domestic law, the punishment of the abusive use of appeals or other actions by the accused or their legal representative that are clearly dilatory.236 210. As the Court has already held with respect to Uruguay, the State must not allow the exercise of actions or appeals to delay and undermine the proceedings nor to impede the victims’ access to justice. Judges, as overseers of the process, must direct and channel judicial proceedings with the goal of not sacrificing justice and due process to 231 Case of Gelman v. Uruguay. Merits and Reparations, para. 253. 232 Case of Gelman v. Uruguay. Monitoring compliance of judgment. Order of the Inter-American Court of March 20, 2013, considering paragraph 101. Case of Gelman v. Uruguay. Monitoring compliance of judgment. Order of the Inter-American Court of March 20, 2013, considering paragraph 94. 233 Case of Gelman v. Uruguay. Monitoring compliance of judgment. Order of the Inter-American Court of March 20, 2013, considering paragraph 98. 234 235 Case of Gelman v. Uruguay. Merits and Reparations, para. 255. 236 Similarly, Case of the Las Dos Erres Massacre v. Guatemala, para. 233. 54