40 breach of order and peace within the jail, is something the authorities of Venezuela must determine. In the opinion of this Court, the facts proven show that the security forces used extreme force with lethal consequences for the life of the 37 inmates of the Reten de Catia Center identified in this judgment, which clearly violated Article 4 of the American Convention. 74. In this sense, the State acknowledged that the actions of the security forces that participated in the abovementioned events were neither proportionate to the then existing threat or danger, nor the strictly necessary to keep the peace and order in the Detention Center of Catia. iii) Creation of legal framework to regulate the use of force 75. As stated in paragraph 66 of this Judgment, the States must pass appropriate legal rules to deter any threat to life. So, domestic law must establish standards clear enough to regulate the use of lethal force and firearms by members of the State security forces. Following the “Principles on the Use of Force and Firearms by the Law Enforcement Officials”. the rules and regulations on the use of firearms by enforcement officias should include guidelines that: (a) specify the circumstances under which law enforcement officials are authorized to carry firearms and prescribe the types of firearms and ammunition permitted; (b) ensure that firearms are used only in appropriate circumstances and in a manner likely to decrease the risk of unnecessary harm; (c) prohibit the use of those firearms and ammunition that cause unwarranted injury or present an unwarranted risk; (d) regulate the control, storage and issuing of firearms, including procedures for ensuring that law enforcement officials are accountable for the firearms and ammunition issued to them; (e) provide for warnings to be given, if appropriate, when firearms are to be discharged; (f) provide for a system of reporting whenever law enforcement officials use firearms in the performance of their duty. 76. Venezuela´s law on the use of force by government authorities, current at the time of the events subject matter of the instant case, did not include the minimum specifications it should have included.132 The characteristics of the issues of fact of the instant case show that the Government armed forces and security agencies were not properly trained to face public disturbances by using means and methods that do not violate human rights. iv) Education and training of government officials on the use of force 77. An adequate legislation would not fulfill its goal if, inter alia, the States do no educate and train the members of their armed forces and security agencies pursuant to the principles and provisions on protection of human rights and the limits to which the use of weapons by law enforcement officials is subject, even under a state of emergency.133 In effect, the European Court of Human Rights held that the matter 132 Cf. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials, supra note 130, Principle 11. 133 Cf. Case of the Caracazo. Reparations (Article 63(1) American Convention on Human Rights) Judgment of 29 de agosto de 2002. Serie C No. 95, para. 127.

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