Immunity for State Forces in Latin America and Northern Ireland: A Comparative Perspective By Gemma Canham, Graduate in Politics and Spanish, Queen's University Belfast


Following the Good Friday Agreement in 1998, a “piecemeal” method of dealing with the past emerged due to that agreement’s lack of an overarching method to confront the legacy of the Troubles.[1] Due to this lack of continuity, the Stormont House Agreement (2014) provided for four measures to fill this gap: (1) an Implementation and Reconciliation Group, (2) an Independent Commission on Information Retrieval, (3) a Historical Investigations Unit and (4) an Oral History Archive.[2] During the negotiations that led to the Agreement, none of the five Northern Ireland political parties or indeed the British or Irish government argued in favour of an amnesty.[3] However, following said agreement and the first ever post Good Friday Agreement prosecutions of the security forces, there have been numerous attempts to promote alternative options allowing for differential application of the law for the security forces that would ultimately lead to impunity for human rights violations.

These alternative options include the following:

  • A ‘qualified’ statute of limitations for current and retired Armed Forces Personnel, which could possibly be extended to the police force.
  • A requirement for the consent of the Attorney General for England and Wales (in their capacity as Advocate General for Northern Ireland) for any prosecutions of former service personnel.
  • A presumption against prosecution when the weapon used was “lawfully supplied”.
  • A power for the Attorney General for Northern Ireland or a Legacy Commissioner to veto prosecutions or inquests into the security forces use of force.[4]

None of these options would be compatible with human rights obligations, the Good Friday Agreement, or the Stormont House Agreement.[5]

Many other countries in situations of conflict, post-conflict, military dictatorship, or transitional justice have aimed to offer preferential treatment to members of the security forces. These measures have included direct or de facto amnesty laws, the use of special courts for the military, or simply not addressing the issue of dealing with the past. Due to its past and present history of conflict, dictatorships and foreign intervention, Latin American countries have many examples of such exclusionary practices, many of which have been brought before the Interamerican system. The following pages illustrate some of these examples and the long-term impunity that has often resulted from them.

Bolivia – Supreme Decree 4078[6]

Supreme Decree 4078 was signed on November 14th, 2019 and was published the following day following a massacre of 11 citizens in the town of Sacaba. The decree aimed to give immunity from criminal prosecution to “Armed Forces personnel participating in the operations to re-establish internal order and stability”.[7] With this same immunity covering them, the armed forces carried out a second massacre on behalf of the interim government at the Senkata Gas Plant in El Alto killing a further 11 citizens. International human rights and humanitarian law experts have declared this law to be illegal under international humanitarian law. The Inter-American Court of Human Rights considers that all amnesty provisions, provisions on prescription and the establishment of measures designed to eliminate responsibility for serious human rights violations are inadmissible and violate Articles 1.1, 2, 8, and 25 of the American Convention on Human Rights.[8] The Inter-American Court of Human Rights has also stated that when the Legislative Power fails to set aside and / or adopts laws which are contrary to the American Convention, the Judiciary is bound to honour the obligation to respect rights as stated in Article 1(1) of the Convention, and consequently, it must refrain from enforcing any laws contrary to such Convention.[9] In response to international and domestic pressure,[10] the Interim Bolivian Government repealed the Supreme Decree on November 28th.[11]

Peru – Ley 26479[12]

On June 14, 1995, the Peruvian Congress unexpectedly and in the early hours of the morning enacted Law No. 26479, also known as the Amnesty Law.[13] Article 1 of this law stated that the amnesty covered all soldiers, police officers, and civil servants being charged, punished, tried, judged, or convicted for civilian or military crimes under either civilian or military law. Article 3 ordered the immediate release of all such persons under arrest, in detention, in prison, or facing jail terms. Article 6 ordered the permanent filing of all legal proceedings, regardless of whether they were still being processed or whether a sentence had already been handed down and placed a ban on fresh investigations into the allegations of those proceedings.[14]

In addition, on June 28, 1995, the government’s congressional majority passed Law No. 26492, the interpretation law of the amnesty law, with which it assumed powers belonging to other branches of government, interfered with the administration of justice, and expanded the grounds for amnesty. This second law declared that the amnesty law neither interfered with the functioning of the courts nor undermined the State’s obligation of respecting and guaranteeing full observance of human rights. Article 2 imposed a ban on judicial review, thus preventing those believing that their rights have been violated from seeking defence through the courts. The second law extended the amnesty to all soldiers, police officers, and civil servants, regardless of whether or not a complaint had been formally made.[15]

These laws attempted to provide immunity for members of the group La Colina, in several high-profile cases. They were also applied retroactively, the amnesty applying for investigations dating back to 1980. Human rights abuses for which the law was applied include the Barrios Altos Massacre[16] and La Cantuta Massacre[17], crimes for which ex-President Alberto Fujimori was eventually extradited and convicted. As soon as Judge Saquicuray’s investigation began, the military courts filed a petition before the Supreme Court claiming jurisdiction in the case, alleging that it related to military officers on active service. However, before the Supreme Court could take a decision on this matter, the amnesty laws were enacted.[18] The few convictions of members of the security forces for human rights violations were immediately annulled. Consequently, eight men who had been imprisoned for the case known as “La Cantuta”, some of whom were being prosecuted in the Barrios Altos case, were liberated.[19]

On March 7, 2000, during its One hundred and sixth session and based on Article 50 of the American Convention, the Interamerican Commission adopted Report No. 28/00, which was transmitted to the State the next day. In this Report, the Commission recommended to the State that: A. […] it annul any domestic, legislative or any other measure aimed at preventing the investigation, prosecution and punishment of those responsible for the assassinations and injuries resulting from the events known as the “Barrios Altos” operation. To this end, the State of Peru should abrogate Amnesty Laws Nos. 26479 and 26492.[20]

In the cases of Barrios Altos and La Cantuta, the Inter American Court of Human Rights ruled that amnesty provisions, provisions on prescription and the establishment of measures designed to eliminate responsibility for serious human rights violations are inadmissible and violate Articles 1.1, 2, 8, and 25 of the American Convention on Human Rights.[21] During the trial, one agent of the Interamerican Commssion stated that “[the trial was about] the deliberate imposition of legislative and judicial mechanisms to prevent the facts being known and prevent those responsible from being punished. It is not only about the gruesome events …, but also about the attitude assumed by the former Government of Peru when it violated its international obligations by adopting laws, with the only purpose of granting impunity. …In the coming days, weeks, months, these obstacles in the Peruvian legislation must be specifically removed so that the Barrios Altos victims may effectively have access to truth and justice and have recourses to enforce their rights before the State of Peru.”[22] In addition, Peruvian courts confirmed that La Colina was not an extra-official group of renegade officers but in fact, an organic part of the Peruvian state.[23]

The amnesty laws were repealed after the end of Fujimori’s presidency in 2000.

Uruguay – The Expiry Law[24]

Following the return to democracy in 1984, as early as April 1985, victims of grave human rights violations and/or their relatives began to bring to the courts cases of human rights abuses perpetrated by security forces during the years of state terrorism. By December 1986, over 700 such cases were under investigation. As a consequence, the armed forces became increasingly restless, openly stating they would not comply with judicial summons to appear in court. The executive portrayed this situation as a possible institutional crisis, pointing to the likelihood of another military coup. In this context, following three previous failed attempts, on 22 December 1986 Parliament enacted the Expiry Law, effectively bringing to an end the possibility of achieving justice and clarifying the past.[25]

The “Expiry Law” was passed with the stated goal of “concluding the transition to the full force of the constitutional order”.[26] The law would bring an end to “the punitive ambition of the state in regards to crimes committed up until March 1st 1985 by military and police officials when fulfilling their role and regarding actions ordered by those in command, either military or political, during the de facto period”.[27] Additionally, the expiry law blurred the boundaries of separation of powers stating in article 3 that judges have to demand – on a case-by-case basis – to the Executive whether the case at hand is covered or not by the Law and article four states that denunciations regarding disappearances presented until December 1986 have to be transmitted to the Executive, which has to order investigations to clarify these facts.[28]

This amnesty violated Uruguay’s obligations under international human rights instruments ratified by that nation[29] as shown in cases that have appeared before the Interamerican Court of Human Rights such as Gelman vs. Uruguay.[30] Despite this judgment and Uruguayan Supreme Court judgments declaring the unconstitutionality of the law and it’s incompatibility with international human rights, the law was upheld twice in referenda carried out in 1989 and 2009. However, questions such as accountability for past human rights crimes cannot be subject to a vote. In these instances, it is a fundamental obligation and duty of the state to clarify these abuses.[31] While the law was finally repealed in 2011,[32] and significant initiatives took place throughout the 2000s in order to move towards accountability for human rights violations,[33] the law created a climate of impunity in Uruguay which still continues to this day. As of 2019, of the 187 criminal investigations opened on these crimes, 91% had not been prosecuted and convictions had been secured in only 14 cases. Out of the 196 enforced disappearances acknowledged by state authorities, the fate of 163 people remained unresolved. The Supreme Court upheld again the statute of limitations for crimes against humanity committed between 1973 and 1985, in breach of international law.[34] The case of Uruguay shows the long term immunity that can be caused by the failure of government to deal with the abuses of the past leaving many victims in limbo for years longer than necessary.

Argentina – Full Stop Law[35] and Due Obedience Law[36]

Following the end of the US-backed military dictatorship in Argentina, the first democratically elected government began carrying out prosecutions of the top military figures for crimes committed during the “dirty war” such as killings and disappearances. However, following threats of a coup d’état by the military, Ley 23492 or La Ley de Punto Final (The Full Stop Law) was passed in 1986, allowing for the cessation of all prosecutions against military and security officers. While this law did not explicitly ban prosecution, it set the impossibly short time frame of 60 days to initiate criminal complaints.[37] Additionally, in 1987, a complementary law, Ley 23521 or La Ley de Obedencia Debida (The Due Obedience Law) was passed. Said law ensured that subordinates that had been carrying out orders could also not be prosecuted. Following pressure from human rights groups such as Las Madres de La Plaza de Mayo, mothers and grandmothers whose sons and grandsons were killed or disappeared, the law was overturned by the National Congress in 2003.[38] Furthermore, the Supreme Court ruled in 2005 that both laws were unconstitutional.

El Salvador – National Reconciliation Law[39] and Law of General Amnesty for the Consolidation of Peace[40]

In 1979, a military junta overthrew General Carlos Romero. While originally made up of both civilian and military members, by January 1980, the military had complete control of the country. A civil war broke out between the government and guerrilla force Frente Farabundo Martí para la Liberación Nacional (Farabundo Martí National Liberation Front (FMLN)). During the course of the civil war, Salvadoran citizens were extra-judicially murdered, disappeared and tortured. The Civil War came to an end in 1992 following a UN negotiated peace treaty.

However, impunity has prevailed in El Salvador. In 1987, during a ceasefire and negotiations, an initial law (Decree 805: Amnesty Act aimed at achieving National Reconciliation) conferring unconditional amnesty on anyone who had been involved in political offences or politically motivated ordinary offences committed prior to 22 October 1987 in which fewer than 20 persons had participated was passed. This option was also applicable to the rebels if they came forward, renounced the use of violence and manifested their desire to be amnestied within 15 days following the promulgation of the Act.[41] This law was immediately critiqued by the international community. The Supreme Court began applying the law in 1988 exonerating the perpetrators of some of the most egregious human rights violations of the civil war including the Las Hojas massacre, the murder of US agrarian reform advisors and the director of ISTA.[42] In addition, a feeling of impunity seemed to prevail as more violations were carried out than in 1987 with army death squads killing 3 times more people, averaging 8 victims per month.

In 1993, the Truth Commission for El Salvador that had investigated human rights abuses during the civil war period published its report finding that of the 22,000 cases of serious acts of violence registered with the commission as taking place between 1980 and 1991, almost 85% were carried out by agents of the state, that is to say members of the armed forces, paramilitary groups allied to the state and the death squads. 5% of cases were reported as having been carried out by the FMLN.[43] The Commission gave certain recommendations in order to allow a modicum of justice for the victims of the atrocities. The key recommendation was for immediate reform of the justice system as the lack of one was a direct barrier to justice and reconciliation in the country. Had the judiciary functioned satisfactorily, not only would the acts which the Commission has had to investigate have been cleared up at the proper time, but the corresponding penalties would have been imposed.[44] That is to say that a country with a fully functioning judicial system should have the capacity to deal with accusations of human rights abuses in a prompt and effective manner.

However, in order to blunt the report’s impact, President Alfredo Cristiani, who had held the presidency since before the end of the civil war, went before the nation on March 14th to ask for an “immediate, general, and total amnesty that will end the temptation to seek revenge.” Cristiani acknowledged the value of “allowing the truth to be made public,” but, invoking the Lord’s Prayer, insisted that “the time has come to forgive.” Cristiani’s appeal for an amnesty even before the Truth Commission’s recommendations were revealed represented an attempt to cut short any effort to face the truth and grapple with its implications.[45]

Directly after the ceasefire in 1992, the National Assembly had passed the National Reconciliation Law which had the support of political parties across the spectrum along with the FMLN and the military and which allowed the FMLN to lay down their weapons without fear of prosecution.[46] This law excluded those that according to the Truth Commission had participated in serious acts of violence since January 1st 1980 whose imprint on society had been such that public knowledge of the truth was urgent, regardless of the jurisdiction to which the case belonged.[47] However, Cristiani’s call for an amnesty was then followed up by the Law of General Amnesty for the Consolidation of Peace which granted a “broad, absolute, and unconditional amnesty” for “all those who participated in criminal acts which occurred before January 1, 1992.” The law stated that such acts included “political crimes or any crime with political ramifications, or ordinary crimes committed by no less than twenty people.”[48]

This Amnesty Law was finally overturned by the Supreme Court as unconstitutional on July 14, 2016.[49] In addition, in 2016, then president Mauricio Funes became the first president in Salvadoran history to acknowledge the crimes against humanity committed by the government during the civil war and to announce reparations for the victims.[50] However, at the end of February 2020, a new “amnesty in disguise” was passed by the Legislative Assembly under the name “Special Transitional Justice, Reparation and National Reconciliation Law” which, according to various human rights organisations shows the members of the assembly ignoring the proposals of the victims and assisting in providing impunity for the aggressors.[51] While the President vetoed the law, stating that “it is an amnesty law, pure and simple,”[52] the fact that the law was passed in the assembly shows that permissiveness for impunity is prevailing throughout the Salvadoran political elite.

Chile – Ley 2191[53]

In 1978, the military dictatorship government headed by Pinochet passed a self-amnesty law for all people who committed crimes in the capacity of authors, accomplices, or accessories since September 11th, 1978 (the start of the regime), as long as they were not convicted or undergoing a trial at the time.[54] Said law legalised and legitimised impunity in Chile for crimes against humanity during the dictatorship[55] despite its incompatibility with constitutional provisions in effect in Chile when it was passed.[56] Chilean courts have ruled it to be constitutional and have applied it in hundreds of cases.[57] In addition, the state kept this law in force after ratifying the American Convention in 1990 despite both the Interamerican Commission and the Interamerican Court declaring that application of the law violated the human rights recognised by the Convention and was incompatible with the Chilean State’s obligations under the Convention.[58]

However, throughout the 1990s, Chilean courts began to re-interpret and find ways to work around the Amnesty Law. For example, several judges ruled that it could only be applied after an investigation. In cases of forced disappearances, as the bodies of the victims had not been found, they held that disappearances were actually crimes of ongoing, aggravated kidnapping. Because the crime had not ended before the 1978 amnesty law cut-off, the amnesty did not prevent the prosecution of the perpetrators.[59] Additionally, in 1998, the Supreme Court held that the law did not apply in cases of crimes against humanity.[60] By July 2003, over 300 military officers had been indicted and dozens had been convicted, many for disappearances that occurred in the early dictatorship years.

Despite these advances, the Amnesty Law continued to be applied by different levels of the Chilean judicial system. Finally, as of 2007, the Supreme Court and Appeal Courts began to declare in a more consistent manner that it was inapplicable.[61] However, despite the continued domestic and Interamerican judgements, the Amnesty Law has still not been formally removed from Chilean Law.

Alongside the general amnesty, following his ousting in 1990, Pinochet continued as Commander in Chief of the Army until 1997 and additionally granted himself a life-long, non-elected seat in the Senate from 1997 giving him Parliamentary immunity from prosecution.[62] In 2000, the Chilean Congress granted yet another layer of immunity to all “former Presidents of the Republic.”[63] Despite these attempts at immunity, several cases were brought against Pinochet, both in Spain, for which then Secretary of State Jack Straw blocked his extradition from the UK on medical grounds, and in Chile itself after his departure from the UK. However, in 2006, Pinochet died without ever having been convicted.

Colombia – Reform of the JEP

Following the end of the armed conflict with the FARC and the signing of a peace treaty in 2016, the Special Jurisdiction for Peace (JEP) was created with specific aims to establish criminal responsibility for the gravest violations committed during the armed conflict, assist in providing reparations, and contribute to reconciliation and peace building.[64] However, upon the election as President of Ivan Duque in 2018, his party began pushing a bill which would radically restructure the JEP creating a separate chamber for trials of military personnel which would take place in secret with judges chosen by the President.[65]

Fortunately, so far, this law has had no success in passing through the legislative assembly. The creation of special chambers for the military would create a scenario of impunity, lack impartiality, and cause the truth to be suppressed. The rights of the victims would not be guaranteed. The special chambers would only generate benefits for the military by thwarting effective investigations.[66]


While no outright amnesty law has been proposed in the Northern Ireland situation, the proposed measures would result in a de facto amnesty that would favourably affect the security forces resulting in impunity for said group. The negative effects of such amnesty measures in Latin America have far outweighed their positives and have been found to be against international conventions time and time again. In approving any such measures for Northern Ireland, the responsible parties would be defying international precedent as well as human rights norms, denying justice to many affected members of the community. The UK cannot reasonably approve this measure and

[1] McEvoy et al., Prosecutions, Imprisonment, and the Stormont House Agreement: A Critical Analysis of Proposals on Dealing with the Past in Northern Ireland (Belfast: Committee on the Administration of Justice, 2020), 6,

[2] UK Government, Stormont House Agreement (London: HM Government, 2014) 6-10,

[3] McEvoy et al. Prosecutions, Imprisonment, and the SHA, 8.

[4] Ibid., 20-29.

[5] Ibid.

[6] Plurinational State of Bolivia, Decreto Supremo 4078 (La Paz: Plurinational State of Bolivia, 2019),

[7] Center for Justice and Accountability, International human rights and humanitarian law experts urge the Bolivian Government and Armed Forces to abide by their international law obligations (San Francisco: Center for Justice and Accountability, 2019), 1,

[8] Barrios Altos v. Peru, Inter-Am. Ct. H.R. (ser.C) No.75, para. 41-42 (2001).

[9] Almonacid-Arellano et al. v. Chile, Inter-Am. Ct. H.R. (ser. C) No.154, para. 123 (2006).

[10] Amnesty International, “Bolivia: Jeanine Añez must immediately repeal decree giving impunity to Armed Forces personnel,” Amnesty International, 18 November 2019,; Center for Justice and Accountability, International Experts Urge Bolivian Government.

[11] TeleSur, “Bolivia Repeals Controversial Immunity Decree for Armed Forces,” TeleSur, 28 November 2019,

[12] Republic of Peru, Ley No. 26479 (Lima: Republic of Peru, 1995),

[13] Inter-American Commission on Human Rights, Report No. 42/99: La Cantuta (Washington DC: Organization of American States, 1999), para. 25,

[14] Ibid., para. 26.

[15] Ibid. para. 27.

[16] “Barrios Altos,” Center for Justice and International Law,

[17] “La Cantuta,” Center for Justice and International Law,

[18] Barrios Altos v. Peru, Inter-Am. Ct. H.R. (ser. C) No.75, para. 2(i) (2001).

[19] Ibid., para. 2(j).

[20] Barrios Altos v. Peru, Inter-Am. Ct. H.R. (ser. C) No.75, para. 17(A) (2001).

[21] Ibid., para. 41-42.

[22] Ibid., para. 36.

[23] “CEJIL Welcomes Conviction of Montesinos and Members of the Colina Group in Peru,” Center for Justice and International Law,

[24] Oriental Republic of Uruguay: Legislative Power, Ley No. 15.848 (Montevideo: Legislative Power of Uruguay, 1986),

[25] “The Many Faces of Impunity: a Brief History of Uruguay’s Expiry Law,” London School of Economics,

[26] Oriental Republic of Uruguay: Legislative Power, Ley No. 15.848, art. 1.

[27] Ibid.

[28] LSE, The Many Faces of Impunity.

[29] Human Rights Watch, Human Rights Watch World Report 1989 – Uruguay, (New York: Human Rights Watch, 1990),

[30] Gelman v. Uruguay, Inter-Am. Ct. H.R. (ser. C) No. 221 (2011).

[31] LSE, The Many Faces of Impunity.

[32] Oriental Republic of Uruguay: Legislative Power, Ley No. 18831,

[33] LSE, The Many Faces of Impunity.

[34] Amnesty International, Uruguay 2019, (London: Amnesty International, 2019)

[35] Republic of Argentina, Ley 23.492, (Buenos Aires: Republic of Argentina, 1986),

[36] Republic of Argentina, Ley 23.521, (Buenos Aires: Republic of Argentina, 1987),

[37] “EIP Explainer: Amnesties Configure,” European Institute of Peace,

[38] BBC News, “Argentina scraps amnesty laws,” BBC News, 21 August, 2003,

[39] Republic of El Salvador, Decreto No. 147, (San Salvador, Republic of El Salvador, 1992),

[40] Republic of El Salvador, Decreto No. 486, (San Salvador, Republic of El Salvador, 1993),,LEGISLATION,,,57f794129,0.html.

[41] The Commission on the Truth for El Salvador, From Madness to Hope: the 12-year war in El Salvador: Report of the Commission on the Truth for El Salvador (New York: United Nations Security Council, 1993), 210,

[42] The Commission on the Truth for El Salvador, From Madness to Hope, 38.

[43] Ibid., 43.

[44] Ibid., 178.

[45] Human Rights Watch, “El Salvador: Accountability and Human Rights: The Report of The United Nations Commission on The Truth for El Salvador,” News from Americas Watch 5, no. 7 (Aug. 1993), 15.  

[46] Ibid., 25.

[47] Republic of El Salvador, Decreto No. 147, art. 6.

[48] Republic of El Salvador, Decreto No. 486, art. 1.

[49] “Transitional Justice in El Salvador: Overturning the Salvadoran Amnesty Law,” Center for Justice and Accountability,

[50] Leah Wilson and Alexis Stoumbelis, “‘Removing the Veil’: El Salvador Apologizes for State Violence on 20th Anniversary of Peace Accords,” NACLA, January 17, 2012,

[51] Jeannette Aguilar and Marcie Mersky, La Desaparición Forzada en el Contexto del Conflicto Armado de El Salvador: Una Primera Aproximación al Fenómeno (San Salvador: CONABÚSQUEDA, 2020),; United Nations, “El Salvador: Legislative Assembly Must Not Pass “De Facto Amnesty” Bill for Rights Violations, say UN Experts,” UN News, 16 May, 2019,; United Nations, “Bachelet Urges El Salvador´s Legislators to Refrain from Reinstating Amnesty for Serious Human Rights Violations,” UN News, 6 March, 2019,

[52] Marcos González Díaz,“Bukele vs Congreso: Cómo la Polémica Ley de Reconciliación en El Salvador Vuelve a Enfrentar al Presidente con la Asamblea,” BBC Mundo, 29 February, 2020,

[53] Republic of Chile, Decreto Ley 2191 (Santiago: Republic of Chile, 1978),

[54] Ibid., art. 1.

[55] REDRESS, Escrito de Solitudes, Argumentos y Pruebas de los Representantes de Señor García Lucero y su Familia Presentado ante la Honorable Corte Interamericana de Derechos Humanos (London: REDRESS, nd), para.32,

[56] Inter-American Commission on Human Rights, Report No. 25/98: Chile (Washington DC: Organization of American States, 1998), para. 35,

[57] Inter-American Commission on Human Rights, Report No. 61/01: Case 11.771, Samuel Alfonso Catalán Lincoleo, Chile (Washington DC: Organization of American States, 2001), para. 50,

[58] Inter-American Commission on Human Rights, Report No. 25/98, para. 71; Almonacid-Arellano et al. v. Chile, Inter-Am. Ct. H.R. (ser. C) No.154, para. 119 (2006).

[59] Stacie Jonas, “The Ripple Effect of the Pinochet Case,” Human Rights Brief 11, no. 3 (2004), 36.

[60] “Ley de Amnistía N°2191,” Museo de la Memoria y los Derechos Humanos,

[61] REDRESS, Escrito de Solitudes, Argumentos y Pruebas de García Lucero, para. 73.

[62] Cath Collins, “Human Rights Trials in Chile during and after the ‘Pinochet Years,’” International Journal of Transitional Justice 4, no. 1 (2010), 76.

[63] Stacie Jonas, The Ripple Effect, 36.

[64] “One Rule for the Military, Another for the Rest? Special Courts and Hiding Accountability in Colombia,” Rights NI,

[65] El Espectador, “El Proyecto que Busca Crear Salas Especiales para Juzgar Militares en la JEP,” El Espectador, 27 September 2018,

[66] “One Rule for the Military,” Rights NI.