38 requires that the right to life be interpreted and enforced so that its guarantees are truly practical and effective (effet utile).124 65. In prior cases, the Court has indicated that compliance with the duties imposed by Article 4 of the American Convention, regarding Article 1(1) thereof, not only presupposes that no person can be arbitrarily deprived of his life (negative duty) but also requires, pursuant to the obligation to guarantee the full and free exercise of human rights, that the States adopt any and all necessary measures to protect and preserve the right to life (positive duty) of the individuals under their jurisdiction.125 66. Based on the foregoing, the States must adopt all necessary measures to create a legal framework that deters any possible threat to the right to life; to establish an effective legal system to investigate, punish, and redress deprivation of life by State officials or private individuals;126 and guarantee the right to unimpeded access to conditions for a dignified life.127 Especially, States must see that their security forces, which are entitled to use legitimate force, respect the right of life of the people under their jurisdiction. ii) The right of individuals to avoid being victims of disproportionate use of force and the duty of the State to use such a force only reasonably and under exceptional circumstances 67. The use of force by governmental security forces must be grounded on the existence of exceptional circumstances and should be planned and proportionally limited by the government authorities. In this aspect, the Court has established that force or coercive means can only be used once all other methods of control have been exhausted and failed.128 68. The use of firearms and lethal force against people by law enforcement officers -which must be generally forbidden- is only justified in even more extraordinary cases. The exceptional circumstances under which firearms and lethal force may be used shall be determined by the law and restrictively construed, so that they are used to the minimum extent possible in all cases, but never exceeding that use "absolutely necessary" in relation to the force or threat to be repealed.129 When excessive force is used, any deprivation of life is arbitrary. 124 Cf. Case of Baldeón García, supra note 3, para. 83; Case of Hilaire. Preliminary Objections. Judgment of September 1, 2001. Series C Nº 80, para. 83, and Case of the Constitutional Court. Jurisdiction. Judgment of September 24, 1999. Series C No. 55, para. 36. 125 Cf. Case of Baldeón García, supra note 3, para. 84; Case of Sawhoyamaxa Indigenous Community, supra note 120, para. 120, and Case of the Pueblo Bello Massacre, supra note 6, para. 120. 126 Cf. Case of Baldeón García, supra note 3, para. 85; Case of Sawhoyamaxa Indigenous Community, supra note 120, para. 153, and Case of the Pueblo Bello Massacre, supra note 6, para. 120. 127 Cf. Case of Baldeón García, supra note 3, para. 85; Case of the Indigenous Community Yakye Axa. Judgment of June 17, 2005. Series C No. 125, para. 161, and Case of the “Juvenile Reeducation Institute”. Judgment of September 2, 2004. Series C No. 112, paras. 152 and 153. 128 Cf. Matter of Yare I and Yare II Capital Region Penitenciary Center. Provisional Measures. Order of the Court of March 30, 2006, fifteen whereas clause, and Matter of Monagas Judicial Confinement Center (“La Pica”) Provisional Measures. Court Order of February 9, 2006, seventeenth whereas clause. 129 Cf. ECHR, Case of Erdogan and Others v. Turkey. Judgment of 25 April, 2006. Application No. 19807/92, para. 67; ECHR, Case of Kakoulli v. Turkey. Judgment of November 22, 2005. Application