where “use of force” that could result in the unintentional deprivation of life is permitted, States must adopt all necessary measures to create a legal framework that deters any possible threat to this right.251 188. Furthermore, with regard to law enforcement agents, the IACHR has established that “[F]or a police force to aspire to be respectful of human rights, it should not only be trained in human rights theory but it should organize itself, select its personnel, train constantly and perform its professional functions to ensure the observance of the human rights of the public it serves.”252 The IACHR has also established that “member states have a specific obligation to provide permanent training and instruction to the members of their police forces so that when they use lethal force in their operations, they do so in strict accordance with internationally accepted standards.”253 189. The IACHR has also asserted that even though the State has the right and obligation to use lethal force on certain occasions, this capacity must be restricted to cases of strict necessity and proportionality. Otherwise, “the lethal use of force may constitute an arbitrary deprivation of life or a summary execution.”254 By the same token, the Court has stated that the use of force must be grounded in the existence of exceptional circumstances and should be planned and proportionally limited by the government authorities.255 Thus, the Court has laid down clear rules on the burden of proof when a death is alleged to have occurred as the result of the use of force due to the failure to observe these requirements; that is, “the State has the obligation to give a satisfactory and convincing explanation of the events and to rebut allegations over its liability, through appropriate evidentiary elements.”256 190. That explanation should therefore be subject to the highest standard of scrutiny, given the nature of the events alleged to be a possible arbitrary deprivation of life and the fundamental role that the Convention accords that right. For example, in cases such as Makaratzis v. Greece, the European Court found that under certain circumstances, even assuming that the force was clearly not used with the object of killing a person and for security purposes, if the conduct of State agents in itself generated a risk to the life of the victim, even if he or she managed to survive, it should be examined in the light of the duties deriving from protection of the right to life.257 191. By the same token, the Inter-American Court has indicated that during an incident in which a display of authority is deployed, “insofar as possible, the State agents should assess the situation and draw up a plan of action before intervening.”258 Regarding this same duty, the European Court has emphasized that “[U]nregulated and arbitrary action by State agents is incompatible with effective respect for human rights.” Therefore, policing operations “must be … regulated … within the framework of a system of adequate and effective safeguards against arbitrariness and abuse of force.”259 251 ECHR, Case of McCann and Others v. The United Kingdom. Application No. 27229/95, September 27,1995, § 148; and I/A Court H.R., Case of Zambrano Vélez et al. v. Ecuador. Merits, Reparations, and Costs. Judgment of July 4, 2007. Series C No. 166, Par. 81; I/A Court H.R., Case of Montero Aranguren et al. (Detention Center of Catia) v. Venezuela. Judgment of July 5, 2006. Series C No. 150, Par. 66. 252 IACHR, Report on Citizen Security and Human Rights, OEA/ Ser.L/V/II. Doc. 57, December 31, 2009, Par. 114. 253 IACHR, Report on Citizen Security and Human Rights, OEA/ Ser.L/V/II. Doc. 57, December 31, 2009, Par. 115. 254 IACHR, Report No. 58/12. Case 12.606, Brothers Landaeta Mejías v. Venezuela, March 21, 2012, Par. 186. 255 I/A Court H.R., Case of Montero Aranguren et al. (Detention Center of Catia), Judgment of July 5, 2006. Series C No. 150. Par. 67. 256 I/A Court H.R., Case of Zambrano Vélez et al. v. Ecuador. Merits, Reparations, and Costs. Judgment of July 4, 2007. Series C No. 166. Par. 108; I/A Court H.R., Case of Montero Aranguren et al. (Detention Center of Catia), Judgment of July 5, 2006. Series C No. 150. Par. 80; I/A Court H.R., Case of Baldeón García. Judgment of April 6, 2006. Series C No. 147. Par. 120. 257 ECHR, Case of Makaratzis v. Greece. Application No. 50385/99/95, December 20, 2004, § 55. 258 I/A Court H.R., Case of Nadege Dorzema et al. v. Dominican Republic. Merits, Reparations, and Costs. Judgment of October 24, 2012 Series C No. 251, Par. 81. 259ECHR, Case of Makaratzis v. Greece. Application No. 50385/99/95, 20 December 2004, § 58.