55. The Commission has also stated that the use of force may be justified, for example, in situations of self-defense or to disarm individuals involved in an armed conflict. Nevertheless, if a person is deprived of his life as a result of the use of lethal force in an excessive and disproportionate manner by State agents responsible for the maintenance and preservation of domestic order it must be considered arbitrary. 47 Likewise, the Court has stated that the use of force by governmental security forces must be based on the existence of exceptional circumstances and should be planned and proportionally limited by the government authorities. In this aspect, the Court has established that force or coercive means can only be used once all other methods of control have been exhausted and failed. 48 56. According to the Court, in exceptional circumstances, the use of firearms and lethal force against people by law enforcement officers -which must be generally forbidden- is only justified in even more extraordinary cases. The exceptional circumstances under which firearms and lethal force may be used shall be determined by the law and restrictively construed, so that they are used to the minimum extent possible in all cases, but never exceeding that what is "absolutely necessary" in relation to the force or threat to be repelled. 49 When excessive force is used, any deprivation of life is arbitrary. 50. 57. When it is alleged that a death has occurred as a result of the excesive use of lethal force, the Inter-American Court has defined clear rules on the burden of proof. In words of the Court: [W]henever the use of force [by state agents] results in death or injuries to one or more individuals, 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. 51 58. Specifically the Court has stated that it is the duty of the State to demonstrate that State authorities attempted to use less lethal means of intervention in the specific case and this failed, and that the action of its security forces was necessary and proportional in relation to the exigencies of the situation, particularly the threat the victim represented.52 59. In relation to the right to personal liberty, the Inter-American Court has pointed out that according to the dispositions of Article 7(1) of the Convention, the protection of liberty safeguards “both the individuals’ physical liberty and their personal safety, in a context in which the lack of guarantees may result in the subversion of the rule of law and in the deprivation of the minimum forms of legal protection against detainees” 53 The Commission recalls that according to the jurisprudence of the Inter-American Court, when it 47 IACHR, Case 10.559. Chumbivilcas v. Perú. Report 1/96. 1 March 1996; IACHR. Case 11.291. Carandiru v. Brasil. Report 34/00. 13 April 2000. paras. 63, 67, 91. 48 I/A Court H.R., Case Montero Aranguren et al. (Detention Center of Catia), Judgment of July 5, 2006. Series C No. 150. para. 67. I/A Court H.R., Case Montero Aranguren et al. (Detention Center of Catia), Judgment of July 5, 2006. Series C No. 150. para. 68. Similarly see ECHR, Case of Erdogan and Others v. Turkey. Judgment of 25 April, 2006. Application No. 19807/92, para. 67; ECHR, Case of Kakoulli v. Turkey. Judgment of November 22, 2005. Application No. 38595/97, para. 107-108; ECHR, Case of McCann and Others v. the United Kingdom. Judgment of September 27, 1995. Series A No. 324, paras. 148-150 and 194; Código de Conducta para Oficiales de Seguridad Pública adopted by the General Assembly of the United Nations, Resolution 34/169, dated December 17, 1979, Article 3. 49 50 I/A Court H.R., Case Montero Aranguren et al. (Detention Center of Catia), Judgment of July 5, 2006. Series C No. 150. para. 68. Similarly see Basic Principles on the Use of Force and Firearms by Law Enforcement Officials Adopted by the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, Cuba, 27 August to 7 September 1990, Principle 9. 51 I/A Court H.R., Case Zambrano Vélez et al. v. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166. para. 108; I/A Court of H.R. Case Montero Aranguren et al. (Detention Center of Catia), Judgment of July 5, 2006. Series C No. 150. para. 80; I/A Court H.R., Case of Baldeón-García. Judgment of April 6, 2006. Series C No. 147, para. 120. 52 I/A Court H.R., Case Zambrano Vélez et al. v. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166. para. 108 53 I/A Court H.R., Case García Asto and Ramírez Rojas. Judgment of November 25, 2005. C Series No. 137, para. 104; Case of Acosta-Calderón. Judgment of 24 June 2005. C Series No. 129, para. 56; Case of Tibi. Judgment of September 7, 2004. C Series No. 114, para. 97; and Case of the Gómez-Paquiyauri Brothers. Judgment of July 8, 2004. C Series No. 110, para. 82.