36 the Convention on the Rights of the Child, a sentence of life imprisonment can be given provided the possibility of release or parole exists. It is important to point out that the trend today is toward eliminating the possibility of life sentences in the case of offenses committed by juveniles, a trend that the Commission believes comports with the obligation under the American Convention, which is to provide special measures of protection for children. In its General Comment No. 10 on Children’s Rights in Juvenile Justice, the Committee on the Rights of the Child recommended abolition of life imprisonment based on the fact that “life imprisonment of a child will make it very difficult, if not impossible, to achieve 129 the aims of juvenile justice despite the possibility of release.” 155. As for the scope of the possibility of release, the Committee on the Rights of the Child has interpreted this provision and observed that “the possibility of release should be realistic and regularly 130 considered.” 156. As for a periodic review, the Committee on the Rights of the Child has emphasized that the child or adolescent “sentenced to this imprisonment should receive education, treatment, and care aiming at his/her release, reintegration and ability to assume a constructive role in society. This also requires a regular review of the child’s development and progress in order to decide on his/her possible 131 release.” 157. Apart from the limitation expressly stated in Article 37(a) of the Convention on the Rights of the Child, the imposition of a sentence of life imprisonment when a child or adolescent is involved must also be examined as a function of the previously mentioned general principles governing the exercise of 132 the State’s punitive authority in the case of children and adolescents. 158. This means that given the particularly harsh nature of a sentence of life imprisonment, such a sentence must be evaluated with special rigor to ensure not only the possibility of release but also the observance of the international standards in the area of juvenile criminal justice, as described in this section. The possibility in law of release is not in itself sufficient to make the imposition of a life sentence on a child or adolescent compatible with the international obligations requiring special protection for children and the purpose that punishment is intended to serve under the American Convention. In each case, the opportunities for a periodic review should be assessed, as should the strict observance of the principles governing the State’s exercise of its punitive authority vis-à-vis children. 159. In conclusion, the Inter-American Commission deems that articles 19 and 5(6) of the American Convention, read in combination and interpreted in light of the standards outlined in the preceding paragraphs, include: i) the States’ obligation to order the measures necessary so that the criminal justice system, as applied to children and adolescents, takes their particular circumstances and needs for protection into account and, accordingly, establishes regulations different from those that regulate the criminal justice system as applied to adults; ii) the States’ obligation to ensure that a sentence of deprivation of liberty is established as “a measure of last resort” and “for the shortest appropriate period of time”; given the severity of a penalty of life imprisonment, special care must be taken when considering these factors; and iii) the States’ obligation to ensure that the number of years a person serving a life sentence must serve in order to be eligible for parole is reasonable and proportional given the special situation of adolescents and the objective of re-socialization as the primary function that the penalty is to serve. 129 Committee on the Rights of the Child, General Comment No. 10 (2007), Children’s Rights in Juvenile Justice, para. 77. 130 Committee on the Rights of the Child. General Comment No. 10 (2007) Children’s Rights in Juvenile Justice, para. 77. 131 Committee on the Rights of the Child. General Comment No. 10 (2007) Children’s Rights in Juvenile Justice, para. 77. 132 In interpreting the Convention on the Rights of the Child, the Committee on the Rights of the Child has written that “In the administration of juvenile justice, States parties have to apply systematically the general principles contained in articles 2, 3, 6 and 12 of CRC, as well as the fundamental principles of juvenile justice enshrined in articles 37 and 40.” Committee on the Rights of the Child. General Committee No. 10 (2007), Children’s Rights in Juvenile Justice, para. 5.