policies in relation to the use of force and identify strategies to implement the Basic Principles on the Use of Force and the Code of Conduct.501 Moreover, the State must provide courses for its agents to ensure they know the legal provisions that allow the use of firearms and that they have adequate training so that if they are ever faced with a decision on whether to use them, they have the necessary knowledge to do so. 502 471. As for the request to adopt suitable protocols that limit the use of force by security officers, the Court cautions that it has not declared a violation of the American Convention based on a failure to upgrade legislation on the use of force. The Court understands, in this regard, that there is no causal nexus with the facts of the case at hand, as the planning of operation “Nipón 96” was a reaction to exceptional circumstances unrelated to the daily work of security forces. This is why the Court finds that such a measure would out of order. 472. The Court recalls, regarding the request to order human rights training for members of the military and the police, that it has already ordered the State of Peru to hold ongoing human rights training courses to military and police forces in the cases of La Cantuta,503 Anzualdo Castro,504 Osorio Rivera505 and Espinoza Gonzales,506 and therefore it would be unnecessary to order the same measure in this case. 473. As for the request to adopt or revise appropriate protocols for investigating violations involving the right to life and the right to personal integrity, the State submitted copies of several protocols507 developed for the investigation of violent death, torture, the scene of the crime, and more, which are already being used by the Forensic institute and the National Directorate of Criminology. The Inter-American Commission and the representatives said nothing about any of the instruments submitted by the State. The Court recalls that the State must prevent the recurrence of human rights violations such as those that occurred in the instant case, and with this intent, adopt all necessary legal, administrative and other types of measures to prevent similar incidents from occurring in the future. 474. The Court has ordered the States in other cases to upgrade the parameters for investigating extrajudicial executions and torture and for conducting forensic examinations, based on international standards.508 In the instant case, the Court holds that the State must continue with the process of implementing effective protocols for investigation of violations involving the right to life as provided in relevant international standards, such as the United Nations Manual on the Effective Prevention and Investigation of Extra-legal, Arbitrary and Summary Executions. It must also provide the institutions responsible for preventing and investigating extrajudicial executions with sufficient human, economic, logistical and scientific Cf. Case of Montero Aranguren et al. (Detention Center of Catia) v. Venezuela, supra, para. 75, and Case of Landaeta Mejías Brothers et al. v. Venezuela, supra, para. 126. 501 Cf. Case of the Caracazo v. Venezuela. Reparations and Costs, supra, para. 143(4)(a), and Case of Landaeta Mejías Brothers et al. v. Venezuela, supra, para. 126. 502 503 Cf. Case of La Cantuta v. Peru, supra, para. 240. 504 Cf. Case of Anzualdo Castro v. Peru, supra, para. 193. 505 Cf. Case of Osorio Rivera and family v. Peru, supra, para. 274. 506 Cf. Case of Espinoza Gonzáles v. Peru, supra, paras. 236 and 327. Cf. Forensic protocols and manuals (evidence file, volumes IX, X and XI, annex 3 to the State’s answering brief, folios 6140 to 7208). 507 Cf. Case of Carpio Nicolle et al. v. Guatemala. Merits, Reparations and Costs. Judgment of November 22, 2004. Series C No. 117, para. 135, and Case of Gutiérrez Soler v. Colombia. Merits, Reparations and Costs. Judgment of September 12, 2005. Series C No. 132, paras. 109 and 110. 508

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