[Expiry Law] does not represent any obstacle for the investigation of the facts of the case.”259 238. In addition, at the public hearing, the Commission referred to other actions and underscored “the importance that the judicial apparatus be strengthened through budget coordination, institutional design and the permanent training of justice operators to effectively investigate these serious violations, incorporating a focus of gender in investigations, especially in those case in which the victims are women.”260 239. The representative, in its brief with petitions and motions, joined the request made by the Commission in its Report on the Merits. With respect to the Expiry Law, it pointed out that it “continues to be an obstacle because it has a widespread effect in the legal community, connected with the use of prescription,” since “the issue of the nonapplicability of the statute of limitations” has not been clearly resolved.”261 It recalled that IELSUR proposed the enactment of an “interpretation” of Article 72 of the Constitution under the Legislature’s authority pursuant to Article 85(20) of the Constitution. It considered that such a law should expressly state that the rights recognized in human rights treaties form part of those that are “inherent to the human personality or derive from the republican form of government.” It explained that it is not sufficient for a state to ratify human rights treaties, especially in the case of Uruguay where there is no agreement (neither doctrinal nor jurisprudential) on the normative hierarchy of those instruments.” 240. With respect to the above, the representative referred to the State’s comments on the creation of an Office of the Special Prosecutor (infra paras. 241 and 242). It recognized that this implied “progress,” but maintained that “other than the good will and the efforts of the Prosecutor [in charge] and his team, 262 this Office does not have sufficient resources to deal, in time and in form, with its enormous task.” 241. The State explained that there were “three basic phases” that “clarify” the events that occurred during the civil-military dictatorship that governed between 1973 and 1985: (a) the non-judicial institutional investigations carried out when the Expiry Law The Commission, in the public hearing, added that “it underscores the importance that the judicial authorities promptly resolve any request of statutory limitations taking into account the non-applicability of the statute of limitations for serious violations in accordance with inter-American standards.” 259 In its final written arguments, the Commission added that, according to the comments of the organizations of civil society in a thematic hearing before the Commission, which was not directly related to the case, “to date there are no judicial protocols on sexual violence, nor any convictions for sexual violence that occurred during the dictatorship.” (The Commission alluded to the thematic hearing, held in March 2021, on “Access to the truth, justice and reparation with a perspective of gender in Uruguay.”) 260 The representative affirmed that, while Law 18,831 declared that the crimes included in the Expiry Law are crimes against humanity and that, therefore, because those crimes “become imprescriptible,” the Supreme Court has admitted remedies of unconstitutionality of Law 18,831. It averred that “the Uruguayan Supreme Court has exercised control of constitutionality regarding [Law 18,831] in some 100 cases between 2013 and 2021, the results of which fluctuate depending on the composition of that body and that in [July 2021, when the final written arguments were presented] it was inclined to declare the law unconstitutional and, therefore, did not apply it in the specific case. Taking into consideration that, in the Uruguayan legal order, trials are suspended when an objection of unconstitutionality is presented, the use of this remedy became part of the extended dilatory practice of the accused in cases involving the investigation into crimes against humanity.” 261 It highlighted that the Office of the Special Prosecutor for Crimes against Humanity has “one prosecutor and two deputy prosecutors.” 262 61