94 [the] 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 Article 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.253 158. Therefore, the Court concludes that the extra-legal execution of Myrna Mack Chang was the result of a covert military intelligence operation prepared by the high command of the Presidential General Staff carried out by its members within a pattern of selective extra-legal executions, in a climate of impunity, which was and has been tolerated by various State authorities and institutions, for which reason it finds that Guatemala has violated Article 4(1) of the American Convention, in combination with Article 1(1) of that same Convention, to the detriment of Myrna Mack Chang. X VIOLATION OF ARTICLES 8, 25 AND 1(1) (RIGHT TO FAIR TRIAL, JUDICIAL PROTECTION AND OBLIGATION TO RESPECT RIGHTS) Pleadings of the Commission 159. In its application, the Commission asked the Court to find that there was a violation of Articles 8 and 25 of the American Convention to the detriment of the victim and her next of kin. In this regard, the Commission pointed out that: a) the judicial proceeding that stemmed from the murder of Myrna Mack Chang is one of the clearest examples in recent Guatemalan history and of the limits of the scope of the willingness of the Guatemalan State to seriously and effectively investigate human rights violations, to try and to punish all those responsible, in this case including the accessories. This case exemplifies the limits of the cloak of impunity that exists in Guatemala and the price that those who attempt to challenge the limits of impunity or to completely lift its mantle must be willing to pay; b) the consequences of challenging impunity have been: the murder of police investigator José Mérida Escobar, who reported that the killing of Myrna Mack Chang was due to a political matter and that a member of the Presidential General Staff was involved in the crime; demotion within the police force and subsequent exile due to threats and acts of intimidation against the other police investigator, José Pérez Ixcajop, who together with Mérida Escobar also stated that the murder of Myrna Mack Chang was a political crime and that there were security agents involved in it; exile of 4 witnesses due to the death threats and intimidations once the facts were make known; exile due to death threats and intimidation against the judge who ordered the trial to commence against the accessories of the murder; 253 Cf. 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., McCann and Others v. the United Kingdom judgment of 27 September 1995, Series A no. 324, para. 161.