111 international standards for the protection of children and involved, inter alia, “generalized, abusive and arbitrary” recourse to preventive detention and unwarranted delays in deciding cases. That being the case, the Commission and the representatives reasoned that in the case of these practices alleged to be in violation of international provisions, the burden of proof falls to the State; in other words, it was Paraguay that had to prove that the inmates’ right to personal liberty was not violated. 227. Taking account of these general comments concerning the right in question, and the special protection required when children are involved, the Court will now examine whether, given the circumstances of the particular case, the State violated the right to personal liberty of each alleged victim. 228. First and foremost, preventive detention is the most severe measure that can be applied regarding to someone accused of a crime. Therefore, it should be reserved for the most exceptional cases, given the limits imposed by the right to presumption of innocence and the principles of necessity and proportionality that are essential in a democratic society.190 229. Preventive detention must strictly conform to the provisions of Article 7(5) of the American Convention: it cannot be for longer than a reasonable time and cannot endure for longer than the grounds invoked to justify it. Failure to comply with these requirements is tantamount to a sentence without a conviction, which is contrary to universally recognized general principles of law.191 230. When preventive detention is ordered for children, the rule must be applied with even greater rigor, since the norm should be measures that are alternatives to preventive imprisonment. Those measures might include the following: strict supervision; permanent custody; foster care; removal to a home or educational institution; care, guidance and supervision orders; counseling; probation; education and vocational training programmes and other alternatives to institutional care.192 The purpose of these alternative measures is to ensure that children are dealt with in a manner appropriate to their well-being and proportionate both to their circumstances and the offence.193 This principle is provided for in various international instruments and rules.194 231. When, however, preventive detention is deemed necessary in the case of a child, it must be for the shortest period possible, as provided in Article 37.b) of the 190 Cf. Case of Suárez Rosero. Judgment of November 12, 1997. Series C No. 35, para. 77. 191 Cf. Case of Suárez Rosero, supra note 190, para. 77. See also Rule 13.2 of the United Nations Standard Minimum Rules for the Administration of Juvenile Justice (Beijing Rules), adopted by the General Assembly in its resolution 40/33 of 28 November 1985; and Rule 17 of the United Nations Rules for the Protection of Juveniles Deprived of Their Liberty, adopted by the General Assembly in resolution 45/113 of 14 December 1990. 192 Cf. Article 40.4 of the Convention on the Rights of the Child. 193 Supra note 192. 194 Cf. Rule 13.1 of the United Nations Standard Minimum Rules for the Administration of Juvenile Justice (Beijing Rules), adopted by General Assembly in resolution 40/33 of 28 November 1985; Rule 17 of the United Nations Rules for the Protection of Juveniles Deprived of Their Liberty, adopted by the General Assembly in resolution 45/113 of 14 December 1990; articles 37 and 40.4 of the Convention on the Rights of the Child; and Article 10.3 of the International Covenant on Civil and Political Rights.