59 Inter-American Court — has worsened the situation of vulnerability for human rights defenders who report violations committed by paramilitary and public security forces.267 As long as this situation of risk persists, the State’s special duties of prevention and protection are heightened, as is its obligation to investigate, with the utmost diligence, acts and omissions of state agents and private individuals, which strike at the civilian population.268 The Commission therefore reiterates that the State objectively created a situation of risk for its inhabitants and defenders, without adopting all of the necessary and adequate measures to keep the paramilitary groups from being able to continue committing acts such as those that are the subject of this matter. The Commission shall examine the alleged violations of the American Convention and the scope of the duties of prevention and protection in this particular case based on these parameters. 209. As for the third factor, the findings of fact show that several of the events that are the subject of this matter have been contemporary – or their consequences have continued – with the State of internal unrest decreed by President Alvaro Uribe on August 12, 2002, which including its extensions, lasted nine months, the circumstances of which are described above in paragraphs 155-159.269 210. In their submissions, the petitioners claim in a general fashion that the State did not respect the minimum standards of legality and proportionality during said internal state of unrest, in ordering military operations to be conducted that disregarded the minimum guarantees referred to in Article 27 of the American Convention. In response, the State made general reference to the restrictions on human rights allowed under Article 27.1, noting that the criteria of necessity and proportionality in achieving a legitimate purpose were taken into account in conducting Operation Orion, “as a measure taken by the State within its margin of appreciation and in keeping with the duty to ensure fundamental rights in a democratic society.”270 The State has also asserted generically during the merits phase that there is no link between the facts that have given rise to the instant matter and the operations carried out in Comuna 13 in 2002; that several of the facts presented by the petitioners did not occur during those operations; and that the facts under examination were not related to the state of internal commotion decreed on August 11, 2002. The Commission observes that in this matter it does not have sufficient elements to pronounce over the alleged violation of Article 27 of the American Convention. 267 IA Court of HR, Case of Valle Jaramillo et al v. Colombia. Merits, Reparation and Costs. Judgment of November 27, 2008. Series C No. 192, par. 81. 268 IA Court of HR, Case of the Massacre of Pueblo Bello v. Colombia. Judgment of January 31, 2006. Series C No. 140, par. 126. 269 In the relevant admissibility reports pertinent to the cases of Mery Naranjo, Maria del Socorro Mosquera, Ana Teresa Yarce and Luz Dary Bastidas et al, the IACHR noted: As for the arguments on the alleged violation of Article 27 of the American Convention, the petitioners refer to the State of unrest decreed by the President of the Republic on the date when the events took place, alleging the violation of the restrictions on suspension of non-derogable rights in it. The IACHR shall determine in the merits stage whether it should examine the international obligations of the State with regard to this provision. IACHR, Report No. 46/07, Petition 231-05, Admissibility. Mery Naranjo et al (Comuna 13), Colombia, July 23, 2007, par. 43; IACHR, Report No. 4/07, Petition 1147-04, Admissibility, Luz Dary Ospina Bastidas et al (Comuna 13), Colombia. February 27, 2007, par. 34. 270 Note DIDHD/GOI No. 77119/2954 from the Colombian State, November 15, 2012, p. 23; Colombian State’s Note DH. GOI No. 12442-0552 dated March 15, 2007, pg. 6.