49 conditions for this type of facts to occur again, which is contrary to the duty to respect and ensure the right to life.111 131. In this regard, safeguarding the right to life requires conducting an effective official investigation when individuals lose their life as a consequence of the use of force by agents of the State.112 In this regard, the European Court of Human Rights has stated that a general legal prohibition of arbitrary killing by the agents of the State would be ineffective, in practice, if there existed no procedure for reviewing the lawfulness of the use of lethal force by State authorities. The obligation to protect the right to life under this provision (Art. 2), read in conjunction with the State's general duty [...] to "secure to everyone within their jurisdiction the rights and freedoms defined in [the] Convention", requires by implication that there should be [an] effective official investigation when individuals have been killed as a result of the use of force. 113 132. In this regard, the Court has deemed proven that in the sub judice case there was a pattern of impunity in which, under public pressure, the lowest level direct perpetrators within the Peruvian National Police were tried and convicted (supra para. 67.r),114 while the mastermind or masterminds have not yet been tried and only one has allegedly been identified (supra para. 67.s). Said pattern of impunity is especially grave in the cases of violations of the right to life in the framework of a pattern of systematic human rights violations, including extra-legal executions, as in the instant case, since it fosters a suitable climate for chronic recidivism of said abridgments.115 133. In view of the above, the Court finds that Rafael Samuel Gómez Paquiyauri and Emilio Moisés Gómez Paquiyauri were extra-legally executed, for which reason it deems that Peru violated Article 4 of the American Convention, in combination with Article 1(1) of this same Convention, to the detriment of the aforementioned Rafael Samuel and Emilio Moisés Gómez Paquiyauri. XII RIGHT TO A FAIR TRIAL AND RIGHT TO JUDICIAL PROTECTION 111 Case of Myrna Mack Chang, supra note 5, para. 156. 112 See Case of Myrna Mack Chang, supra note 5, para. 157; and Case of Juan Humberto Sánchez, supra note 15, para. 112. 113 See Eur. Court H.R., Case of Nachova and others v. Bulgaria, Judgment of 26 February 2004, para. 116; Eur. Court H.R., Case of Hugh Jordan v. the United Kingdom, Judgment of 4 May 2001, para. 105; Eur. Court H.R., Case of Çiçek v. Turkey Judgment of 27 February 2001, para. 148; and Eur. Court H.R., Case of McCann and Others v. the United Kingdom, Judgment of 27 September 1995, Series A no. 324, para. 161. 114 The direct perpetrators of the homicides were sentenced to 18 months deprivation of liberty for the principal of the crime and 6 years for the accomplice (supra para. 65.p), which were deemed to have been carried out through application of the prison benefits of semi-liberty and parole, respectively, set forth in the Criminal Enforcement Code under Peruvian legislation (supra para. 65.r). 115 Case of Myrna Mack Chang, supra note 5, para. 156.