241. The representatives also considered that the State was responsible for several threats and acts of harassment against the Sarayaku leaders, which can be attributed to it, because it failed to provide protection, even though measures of protection in their favor granted by the Inter-American Commission on May 5, 2003, were in force. In addition, they argued that despite the complaints filed by those affected, the State has not conducted any investigative measure or announced any punishment. 242. Furthermore, the representatives emphasized that the said violations resulted in the stigmatization of the Sarayaku People as a violent people, and this has adversely affected its members’ relations with the rest of Ecuadorian society, and particularly with neighboring communities. They also indicated that the situation had created distress, anxiety and fear among the members of the Sarayaku and had affected their physical and mental integrity. The representatives asked the Court to declare that the State had violated the right of all members of the Sarayaku People to their personal integrity. 243. Regarding the events of January 25, 2003, the State argued that, without reliable evidence to prove a particular pattern, and direct proof demonstrating the period during which the alleged illtreatment took place, and evidence of the responsibility of State agents, the Court cannot declare the State's responsibility. It also indicated that, in this case, there is no consistent evidence or presumption that could lead the Court to conclude firmly that the presumed victims were subjected to torture or other cruel, inhuman or degrading treatment and, furthermore, with the support or tolerance of government authorities. Therefore, the State could not be declared responsible for acts that have not been reliably proved. B. Considerations of the Court B.1 In relation to the explosives buried on the Sarayaku territory 244. In its consistent case law, the Court has established that the obligations imposed by Article 4 of the American Convention, in relation to Article 1(1) thereof, not only presuppose that no one is to be arbitrarily deprived of his life (negative obligation) but also, in light of their obligation to guarantee the full and free exercise of human rights, States are required to take all appropriate measures to protect and preserve the right to life (positive obligation) of all those who are under its jurisdiction. Special obligations are derived from the general obligations under Articles 1(1) and 2 of the Convention, which can be determined based on the particular needs for protection of the holder of the right, due either to their personal status or to the specific situation in which they find themselves.305 In certain cases, exceptional circumstances have arisen that allow the Court to examine the violation of Article 4 of the Convention in relation to individuals who did not die as a result of the acts that violated the Convention.306 245. It is clear that a State cannot be held responsible for all situations in which the right to life is at risk. Bearing in mind the difficulties involved in the planning and execution of public policies and 305 Cf. Case of the Mapiripán Massacre v. Colombia. Merits, reparations and costs. Judgment of September 15, 2005. Series C No. 134, paras. 111 and 113, and Case of Anzualdo Castro v. Peru. Preliminary objection, merits, reparations and costs. Judgment of September 22, 2009. Series C No. 202, para. 37. Also see Case of Gelman v. Uruguay. Merits and reparations. Judgment of February 24, 2011. Series C No. 221, para. 76. 306 Thus, for example, in the Case of the Yakye Axa Indigenous Community v. Paraguay, the Court declared that the State was responsible for the violation of the right to life, considering that, having failed to ensure the right to communal property, the State had deprived the Community of the possibility of having access to their traditional means of subsistence, as well as the use and enjoyment of the natural resources necessary to obtain clean water and for the practice of traditional medicine for the prevention and treatment of diseases, and for failing to adopt the affirmative measures required to ensure decent living conditions (Case of the Yakye Axa Indigenous Community v. Paraguay, Merits, reparations and costs, para. 158(d) and (e)). See also, Case of the “Children’s Rehabilitation Institute” v. Paraguay. Preliminary objections, merits, reparations and costs. Judgment of September 2, 2004. Series C No. 112, para. 176; Case of the La Rochela Massacre v. Colombia. Merits, reparations and costs. Judgment of May 11, 2007. Series C No. 163, paras. 124, 125, 127 and 128, and Case of Gelman v. Uruguay, para. 130. 69