criminality and organized crime, including measures that entail restrictions or even deprivations of personal liberty. Despite this, the State does not have unlimited power to achieve these ends, irrespective of the gravity of some actions and of the guilt of the alleged perpetrators. In particular, the authorities cannot violate the rights recognized in the American Convention, such as the rights to the presumption of innocence, to personal liberty, and to due process and, among other measures, they cannot carry out unlawful or arbitrary arrests.184 116. The Court has indicated that the essential content of Article 7 of the Convention is the protection of the liberty of the individual against any arbitrary or unlawful interference by the State.185 The Court has also indicated that this article includes two types of regulation: one general and one specific. The general aspect is found in the first paragraph, while the specific aspect is contained in paragraphs 2 to 7; any violation of those paragraphs necessarily results in the violation of Article 7(1) of the American Convention.186 117. An unlawful deprivation of liberty violates Article 7(2) of the Convention, and occurs when the applicable domestic law is not observed.187 The Court has explained that the restriction of the right to personal liberty “is only viable when it occurs based on the causes and conditions previously established by the Constitution or by the laws enacted in conformity with the latter (substantive aspect) and, also, strictly subject to the procedures that they objectively define (formal aspect).”188 Regarding the requirement of lawfulness and the authority of the police to arrest an individual, the Court understands that it should be recalled that improper action by the law enforcement agencies represents “one of the main threats to the right to personal liberty.”189 Therefore, the regulations which determine the authority of police to prevent and to investigate crime must include clear and specific references to parameters that prevent detentions that are arbitrary or contrary to constitutional mandates.190 118. Moreover, it should be noted that the arbitrary nature of a deprivation of liberty, prohibited by Article 7(3) of the Convention, is not distinguished merely by being contrary to the law; rather, it includes elements of impropriety, injustice and unpredictability.191 Accordingly, the deprivation of liberty may be arbitrary if it is conducted based on “reasons and methods that – even though Cf. Mutatis mutandis, Case of Cruz Sánchez et al. v. Peru. Preliminary objections, merits, reparations and costs. Judgment of April 17, 2015. Series C No. 292, para. 262, and Case of Olivares Muñoz et al. v. Venezuela. Merits, reparations and costs. Judgment of November 10, 2020. Series C No. 415, para. 92. 184 Cf. Case of Juan Humberto Sánchez v. Honduras. Preliminary objection, merits, reparations and costs. Judgment of June 7, 2003. Series C No. 99, para. 84, and Case of Palacio Urrutia et al. v. Ecuador. Merits, reparations and costs. Judgment of November 24, 2021. Series C No. 446, para. 130. 185 Cf. Case of Chaparro Álvarez and Lapo Íñiguez v. Ecuador. Preliminary objections, merits, reparations and costs. Judgment of November 21, 2007. Series C No. 170, para. 54, and Case of Palacio Urrutia et al. v. Ecuador, supra, para. 130. 186 187 Cf. Case of Chaparro Álvarez and Lapo Íñiguez v. Ecuador, supra, para. 57, and Case of González et al. v. Venezuela. Merits and reparations. Judgment of September 20, 2021. Series C No. 436, para. 95. 188 Case of Gangaram Panday v. Suriname. Merits, reparations and costs. Judgment of January 21, 1994. Series C No. 16, para. 47, and Case of González et al. v. Venezuela, supra, para. 95. 189 Case of Servellón García et al. v. Honduras. Judgment of September 21, 2006. Series C No. 152, para. 86, and Case of González et al. v. Venezuela, supra, para. 96. 190 Case of Fernández Prieto and Tumbeiro v. Argentina. Merits and reparations. Judgment of September 1, 2020. Series C No. 411, para. 90, and Case of González et al. v. Venezuela, supra, para. 96. 191 Cf. Case of Gangaram Panday v. Suriname, supra, para. 47, and Case of González et al. v. Venezuela, supra, para. 97. 37