the enactment of laws and the implementation of practices leading to the effective observance of those guarantees.” 160 128. Since the parties did not allege the violation of Article 2 of the American Convention, the Court deems it pertinent to apply the iura novit curia principle, which is strongly supported in international case law, and which allows the Court to examine the possible violation of provisions of the Convention that have not been alleged in the briefs presented by the parties, provided that the parties have had the opportunity to state their respective positions in relation to the facts that substantiate this. 161 The Court has used this principle on different occasions since its first judgment 162 to declare the violation of rights that have not been alleged directly by the parties, but that are revealed by the analysis of the facts in dispute, because this principle authorizes the Court to classify the disputed situation or legal arguments differently to the way in which they were classified by the parties, provided that it respect the factual framework of the case. 163 129. Based on the above, the State did not comply, at the time of the facts, with its obligation to ensure the right to life by appropriate legislation on the use of force. Consequently, it also failed to prove that it had provided training on this matter to law enforcement agents, in violation of the obligation to ensure the right to life, and the obligations arising from Article 2 of the American Convention. 164 B.2 Actions at the time of the incident: legitimate purpose, absolute necessity and proportionality, in relation to the obligation to respect rights 130. The Court has indicated that, “during an incident in which force is used, the State agents, insofar as possible, must assess the situation and draw up a plan of action prior to intervening.” 165 Consequently, police operations should be aimed at the arrest of the presumed offender and not at the deprivation of his life. 131. As a general rule, the use of firearms is established as a measure of last resort in light of both domestic and international law. Thus, the Basic Principles on the Use of Force establish that “[l]aw enforcement officials shall not use firearms against persons 160 Cf. Case of Castillo Petruzzi et al. v. Peru. Merits, reparations and costs. Judgment of May 30, 1999. Series C No. 52, para. 207, and Case of Norín Catrimán et al. (Leaders, members and activist of the Mapuche Indigenous People), supra, para. 175. 161 Cf. Case of Velásquez Rodríguez. Merits, supra, para. 163, and Case of Furlan and family members v. Argentina. Preliminary objections, merits, reparations and costs. Judgment of August 31, 2012. Series C No. 246, para. 55. 162 For example, in the following cases, inter alia, the Court declared the violation of rights that had not been cited by the parties in application of the iura novit curia principle: (i) in the case of Velásquez Rodríguez v. Honduras it declared the violation of Article 1(1) of the Convention; (ii) in the case of the Sawhoyamaxa Indigenous Community v. Paraguay it declared the violation of Article 3 of the American Convention; (iii) in the case of the Ituango Massacres v. Colombia it declared the violation of Article 11(2) of the Convention; (iv) in the case of Bueno Alves v. Argentina it declared the violation of Article 5(1) of the American Convention to the detriment of the next of kin of Mr. Bueno Alves; (v) in the case of Kimel v. Argentina it declared the violation of Article 9 of the American Convention; (vi) in the case of Heliodoro Portugal v. Panama it declared the violation of Article I of the Inter-American Convention on the Forced Disappearance of Persons, in relation to Article II of this instrument; (vii) in the case of Bayarri v. Argentina it declared the violation of Articles 1, 6 and 8 of the Inter-American Convention to Prevent and Punish Torture; (viii) in the case of Usón Ramírez v. Venezuela it declared the violation of Article 9 of the American Convention; (ix) in the case of Vélez Loor v. Panama it declared the violation of Article 9 of the American Convention, and (x) in the case of Furlan and family members v. Argentina it declared the violation of Article 5 of this instrument. 163 Cf. Case of Bueno Alves v. Argentina. Merits, reparations and costs. Judgment of May 11, 2007. Series C No. 164, para. 70, and Case of Furlan and family members, supra, para. 55. 164 Cf. Case of Nadege Dorzema et al., supra, para. 82. 165 Cf. Case of Montero Aranguren et al. (Retén de Catia), supra, para. 67, and Case of Nadege Dorzema et al., supra, para. 84. 33