82. As indicated in the general considerations section, the execution by firing squad was a method set forth in the Guatemalan Law at the time of the events. Later, by means of Decree 100-96 of October, 1996, said method was repealed and was replaced with the lethal injection procedure. This was done in considering that “while death penalty is in force in Guatemala, its execution must be carried out in the most humanitarian way possible not only for the convicted that suffers it but also for the society, which in a way or another, is a spectator.” It also considered that “modern trends in Forensic Medicine recommend the use of the procedure of lethal injection, which combines the guarantee of its effectiveness in a very short period of time, with the minimum suffering on the part of the person subject to it (…).”56 VI. ANALYSIS ON THE MERITS A. General considerations on the analysis standard in death penalty cases 83. The Inter-American Commission considers it relevant to reiterate its previous decisions regarding the heightened scrutiny to be used in cases involving the death penalty. The right to life has received broad recognition as the supreme human right and as a condition sine qua non for the enjoyment of all other rights.57 84. For this reason, the IACHR’s duty to ensure that any deprivation of life that may occur by the application of the death penalty does not violate any obligation enshrined in the instruments of the InterAmerican System of Human Rights, is particularly important.58 This rigorous scrutiny is consistent with the restrictive approach adopted by other international human rights bodies when they analyzed cases involving the death penalty59 and the Inter-American Commission has mentioned and applied it in previous cases of death penalty submitted before it.60 85. As the Commission has explained, this standard of review is the necessary consequence of the specific penalty at issue and the right to a fair trial and the attendant due process guarantees.61 The IACHR has stated: 56 Decree Number 100-96 of the Congress of the Republic of Guatemala. 57 IACHR; Report No. 76/16, Case 12.254. Merits. Victor Saldaño. United States of America. December 10, 2016, para.169. 58 See on this regard, IACHR, The Death Penalty in the Inter-American Human Rights System: from Restrictions to Abolition, OEA/Ser.L/V/II.Doc. 68, December 31, 2011. 59 See, for example, I/A Court H.R., Advisory Opinion OC-16/99 (October 1, 1999) “The Right to Information on Consular Assistance in the Framework of the Guarantees of the Due Process of Law,” para. 136 (the finding that “[b]ecause execution of the death penalty is irreversible, the strictest and most rigorous enforcement of judicial guarantees is required of the State so that those guarantees are not violated and a human life not arbitrarily taken as a result;”) HRC-UN, Baboheram-Adhin et al. v. Suriname, Communications Nos. 148-154/1983, approved on April 4, 1985, para. 14(3) (considering that the law must strictly control and limit the circumstances in which a person may be deprived of his life by the authorities of a State;) Report of the UN Special Rapporteur on Extrajudicial Executions, Bacre Waly Ndiaye, submitted in accordance to 1994/82 Order of the Inter-American Commission on Human Rights, Question of the violation of human rights and fundamental freedoms in any part of the world with particular reference to colonial and other dependent countries and territories, UN Doc.E/CN.4/1995/61 (December 14, 1994) (hereinafter the “Ndiaye Report”), para. 378 (in which it is highlighted that in cases related to the death penalty, the observance of all the rules for an impartial trial to each and every of the cases is what must be guaranteed and when there is indicia to the contrary, verified in accordance with the obligation that international law imposes, to conduct exhaustive and impartial investigations of all the claims of a violation to the right to life.) 60 IACHR, Report 11/15, Case 12.833, Merits (Publication,) Félix Rocha Díaz, United States of America, March, 23, 2015, para. 54; Report No. 44/14, Case 12.873, Merits (publication,) Edgar Tamayo Arias, United States of America, July 17, 2014, para. 127; Report No. 57/96, Andrews, United States of America, IACHR Annual Report, 1997, paras. 170-171. 61 IACHR, The Death Penalty in the Inter-American System of Human Rights: from Restrictions to Abolition, OEA/Ser.L/V/II.Doc. 68, December 31, 2011, para. 41. 14