A/HRC/45/13/Add.3 the fate of the missing person. An obligation to account for the disappearance and death, and to identify and prosecute any perpetrator of unlawful acts in that connection, will generally remain.” 47. The Human Rights Committee in the case Bleier v. Uruguay considered this case to be admissible as the enforced disappearance was ongoing and related to events after Uruguay’s ratification of the ICCPR and its Optional Protocol 1 on 23 March 1976. The Committee confirmed the continuous nature of enforced disappearances. 164 In the case Sarma v. Sri Lanka the Human Rights Committee also held that the enforced disappearance of the victim was continuous.165 48. The Inter-American Court reiterated the continuous nature of an enforced disappearance, which allows for the Court’s competence to rule on any actions and their consequences taking place in the aftermath of the recognition of jurisdiction 166 In this relation the duty to investigate instances of alleged enforced disappearances is considered to be continuous as long as the fate of the person disappeared has not been clarified.167 The obligation remains in force as long as there is uncertainty around what ultimately happened to individuals who are missing, because the right of victims’ families to know the victim’s fate and, where applicable, to locate their bodily remains, constitutes a fair expectation that the State must meet through all available means.168 49. The Inter-American Court stated in Velásquez-Rodríguez v. Honduras (paragraph 181): “The duty to investigate facts of this type continues as long as there is uncertainty about the fate of the person who has disappeared. Even in the hypothetical case that those individually responsible for crimes of this type cannot be legally punished under certain circumstances, the State is obligated to use the means at its disposal to inform the relatives of the fate of the victims and, if they have been killed, the location of their remains.” E. Autonomy and independence of the authorities in charge of the investigation 50. The persons responsible for the investigation and the ones who carry out that investigation must be impartial and independent from those allegedly involved in the events.169 The European Court discussed the independence and impartiality of adjudicatory authorities relating to cases in Turkey. In these cases the Court concluded that National Security Courts were not sufficiently independent due to the involvement of a military judge in relation to the requirements under Article 6 ECHR. The Court stated, “the court may be unduly influenced by considerations which had nothing to do with the nature of the case.” 170 Elements beyond the institutional and hierarchical organization of courts are considered when assessing the independence of investigations.171 164 165 166 167 168 169 170 171 30 Human Rights Committee, Bleier v. Uruguay (see footnote 138) paras. 7(b), 13, 14. Human Rights Committee, Sarma v. Sri Lanka, Communication No. 950/2000, 16 July 2003, para. 6.2. IACHR, Blake v. Guatemala, Merits. Judgment of January 24, 1998, Series C No. 57, paras. 39 and 40; IACHR, Velásquez-Rodríguez v. Honduras (see footnote 123) para. 155; IACHR, RadillaPacheco v. Mexico, Preliminary objections, Merits, Reparations, and Costs. Judgment of November 23 2009, Series C No. 209, para. 24. IACHR, Velásquez-Rodríguez v. Honduras (see footnote 123) para. 181. See IACHR, García y Familiares Vs. Guatemala, Merits, Reparations and Costs, Judgment of 29 November 2012, Series C No. 258 para. 132; IACHR, Osorio Rivera y Familiares Vs. Perú, Preliminary Objections, Merits, Reparations and Costs, Judgment of 26 November 2013, Series C No. 253, para.179; and IACHR, Rodríguez Vera y otros (Desaparecidos del Palacio de Justicia) Vs. Colombia, Preliminary Objections, Merits, Reparations and Costs, Judgment of 14 November 2014, para. 439. European Court of Human Rights, Tahsin Acar v. Turkey, Application No. 26307/95, 23 November 2004, paras. 221–223; See Section II, F of the Thematic Report. European Court of Human Rights, Mahmut Kaya v. Turkey, Application No. 22535/93, 28 March 2000, para.97. European Court of Human Rights, Tahsin Acar v. Turkey (see footnote 180) para. 221.