On January 7, 2020, the U.N. Human Rights Committee ruled [3] that a communication lodged against Russia by relatives of Polish nationals allegedly killed in the Katyn Massacre was time-barred and therefore inadmissible. The authors of the communication alleged violations of article 2(3) in conjunction with article 6, 7, 14, 17, and 19 of the International Covenant on Civil and Political Rights [4] (the Covenant) and articles 1 and 2 of the Optional Protocol based on claims of a lack of effective investigation into the execution of their prisoner-of-war relatives by Soviet authorities in 1940, as well as ill treatment by the Russian authorities during judicial proceedings which concluded that there was insufficient evidence to establish that the authors' relatives were, in fact, executed in the Massacre. The Committee reiterated "that it is precluded ratione temporis from examining alleged violations that occurred prior to the entry into force of the Covenant for the State party, unless these violations continue after the Covenant and the Optional Protocol became effective for the State party." It noted that, although article 2(3) (right to an effective remedy) and article 6 (right to life) may, in some circumstances require continued investigation into violations that occurred prior to the entry into force of the Covenant, such an obligation will only apply if a violation of article 6 has been "prima facie established or acknowledged." Acknowledging that the rights under articles 2(3) and 6 did not exist before 1976 and were not subject to communication proceedings until 1992, the Committee could not conclude that Russia "still had a continuous obligation to investigate the 1940 killings." The Committee cited the "significant passage of time from the events of 1940 and absence of a formal acknowledgement by the State party of the violation of the authors' relatives[sic] rights in the interim." The Committee further decided that the authors' article 7 arguments were unsubstantiated in view of both the large passage of time and the lack of evidence on file demonstrating treatment by the State party that was "manifestly disrespectful or degrading or otherwise aimed at causing them pain and suffering." Two Committee members dissented on the Article 7 claim.