242. Subparagraph (f) of Article 8(2) of the Convention establishes the “minimum guarantee” of “the right of the defense to examine witnesses present in the court and to obtain the appearance, as witnesses, of experts or other persons who may throw light on the facts,” which underlies the adversarial principle and the principle of procedural equality. The Court has indicated that, among the guarantees recognized to the accused, is that of examining the witnesses for and against them, under the same conditions in order to defend themselves.265 The anonymity of the witness restricts the exercise of this right, because it prevents the defense from asking questions related to the possible hostility, prejudice and reliability of the deponent, as well as other that would allow arguing that the testimony is untruthful or erroneous.266 243. The State’s duty to ensure the rights to life and to personal integrity, liberty and safety of those who testify in criminal proceedings may justify the adoption of measures of protection. In this regard, the laws of Chile include both procedural measures (such as maintaining the confidentiality of personal information or physical characteristics that identify a person), and extra-procedural (such as protection of personal safety). 244. In the instant case, the Court will limit its analysis to deciding whether the procedural measure of preserving the anonymity of witnesses, which was applied in the criminal proceedings held against three of the presumed victims (supra paras. 232 to 236), entailed a violation of the right of the defense to examine the witnesses. This measure is regulated in Chile as described in paragraph 232 and, in this regard, the Supreme Court has stated that: […] such a serious decision may only be taken in each particular case and with complete awareness of the specific circumstances. These are exceptional measures for exceptional situations and are always adopted with absolute control over those who intervene so that the harm to the exercise of any of the rights of the defense in a trial are minimum, and that it never obstructs or limits the exercise of the essence of this guarantee.267 245. The Court will now examine whether, in the above-mentioned trials of these three presumed victims in this case, the measure of preserving witness anonymity was adopted subject to judicial control,268 based on the principles of necessity and proportionality, taking into account that this is an exceptional measure and verifying the existence of a situation of risk for the witness.269 When making this assessment, the Court will bear in mind the impact that the measures had on the right of defense of the accused. 246. In order to rule in the instant case, the Court will also take into consideration whether, in the specific cases, the State ensured that the effects on the right of defense of the accused that results from the use of the measure of preserving the anonymity of witnesses was sufficiently offset by counterbalancing measures, such as:270 (a) the judicial authority must be aware of the 265 Cf. Case of Castillo Petruzzi et al. v. Peru, Merits, reparations and costs, para. 154, and Case of J. v. Peru, para. 208. 266 Cf. ECHR, Case of Kostovski v. The Netherlands, No. 11454/85. Judgment of 20 November 1989, para. 42. 267 In its brief with final arguments, the State transcribed parts of a ruling of the Supreme Court of Justice of March 22, 2011, “on the application for a declaration of nullity of the judgment delivered by the Cañete Oral Criminal Court” (merits file, folio 2140 to 2142). 268 Mutatis mutandi, ECHR, Case of Doorson v. The Netherlands, No. 20524/92. Judgment of 26 March 1996, paras. 70 and 71; Case of Visser v. The Netherlands, No. 26668/95. Judgment of 14 February 2002, paras. 47 and 48; Case of Birutis and Others. v. Lithuania, Nos. 47698/99 and 48115/99. Judgment of 28 June 2002, para. 30, and Case of Krasniki v. the Czech Republic, No. 51277/99. Judgment of 28 May 2006, paras. 79 to 83. 269 Cf. ECHR, Case of Krasniki v. The Czech Republic, No. 51277/99. Judgment of 28 May 2006, para. 83, and Case of Al-Khawaja and Tahery v. The United Kingdom, Nos. 26766/05 and 22228/06. Judgment of 15 December 2011, paras. 124 and 125. 270 Cf. ECHR, Case of Doorson v. The Netherlands, para. 72; Case of Van Mechelen and Others v. The Netherlands, Nos. 21363/93, 21364/93, 21427/93 and 22056/93. Judgment of 23 April 1997, paras. 53 and 54, and Case of Jasper v. The United Kingdom, No. 27052/95. Judgment of 16 February 2000, para. 52. 86