26 never exceeding what is "absolutely necessary" given the force or threat to be repelled.86 When excessive force is used, any deprivation of life is arbitrary.87. 136. When a death is claimed to be the result of the excessive use of force, the InterAmerican Court has established clear rules regarding the burden of proof. As the Court wrote: whenever the use of force [by state agents] results in death or injuries to one or more individuals, the State has the obligation to give a satisfactory and convincing explanation of the 88 events and to rebut allegations over its liability, through appropriate evidentiary elements. 137. More specifically, when providing its explanation of the use of force, the State must show that its authorities attempted less lethal means of intervention that were unsuccessful, and that the action of its security forces was both necessary and proportional in relation to the exigencies of the situation, particularly the threat the situation posed to the victim.89 138. The Court has also held that the State’s obligation to respect the right to life of every person under its jurisdiction has special connotations in the case of children, as evident from the provisions regarding protection of children set forth in the American Convention and in the Convention on the Rights of the Child. The right of the child to special protection creates an obligation for the State, which is to prevent situations that might lead, either by action or omission, to a violation of the child’s right to special protection.90 The State, therefore, must take on the special role of guarantor with even greater care and an even greater sense of responsibility, and must take special measures to that end.91 139. For its part, the European Court of Human Rights has described what an effective investigation capable of evaluating the legality of the lethal use of force must involve. According to that Court, 86 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 No. 38595/97, para. 107-108; ECHR, Case of McCann and Others v. the United Kingdom. Judgment of September 27, 1995. Series A No. 324, paras. 148-150 and 194; Code of Conduct for Law Enforcement Officials, adopted by the General Assembly of the United Nations, Resolution 34/169, dated December 17, 1979, Article 3. 87 I/A Court H.R., Case of Montero Aranguren et al. (Detention Center of Catia) v. Venezuela, Judgment of July 5, 2006. Series C No. 150, paragraph 68. Similarly see also: the Basic Principles on the Use of Force and Firearms by Law Enforcement Officials, adopted by the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, Cuba, August 27 to September 7, 1990, Principle 9. 88 I/A Court H.R., Case of Zambrano Vélez et al. v. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166, paragraph 108; I/A Court H.R. Case of Montero Aranguren et al. (Detention Center of Catia) v. Venezuela, Judgment of July 5, 2006. Series C No. 150, paragraph 80; I/A Court H.R., Case of Baldeón García v. Argentina. Judgment of April 6, 2006. Series C No. 147, paragraph 120. 89 I/A Court H.R., Case of Zambrano Vélez et al. v. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166, paragraph 108. 90 91 I/A Court H. R., Bulacio v. Argentina Case. Judgment of September 18, 2003. Series C No. 100, pars. 138. I/A Court H. R., Gómez Paquiyauri Brothers v. Peru Case. Judgment of July 8, 2004. Series C No. 110, pars. 124, 163164, and 171; I/A Court H. R., Bulacio v. Argentina Case. Judgment of September 18, 2003. Series C No. 100, pars. 126, 133 and 134; and I/A Court H. R., Juridical Condition and Human Rights of the Child. Advisory Opinion OC-17/02 of August 28, 2002. Series A No. 17, par. 60.