B.2. Arbitrariness of the criminal sanctions 161. Article 7(3) of the Convention stipulates that “[n]o one shall be subject to arbitrary arrest or imprisonment.” The Court has established on other occasions that “no one shall be subject to arrest or imprisonment for reasons and by methods that, although classified as legal, may be considered incompatible with respect for the fundamental rights of the individual because, among other factors, they are unreasonable, unpredictable, or disproportionate. 232 In addition, Article 37(b) of the Convention on the Rights of the Child establishes that States must ensure that “[n]o child shall be deprived of his or her liberty unlawfully or arbitrarily.” This means that if judges decide that it is necessary to apply a criminal sanction, and if this is deprivation of liberty, even though this is provided for by law, its application may be arbitrary if the basic principles that regulate this matter are not considered. 162. Particularly with regard to measures or sentences involving the deprivation of liberty of children, the following principles apply, above all: (1) ultima ratio and as short as possible, which in the terms of article 37(b) of the Convention on the Rights of the Child, means that “[t]he arrest, detention or imprisonment of a child […] shall only occur as a last resort and for the shortest appropriate period of time”; 233 (2) temporal determination from the moment they are imposed, particularly related to the former, because if deprivation of liberty must be the exception and for as short a time as possible, this means that prison sentences with an indeterminate duration or that involve the absolute deprivation of this right must not be applied to children, and (3) periodic review of the measures of deprivation of liberty of children. In this regard, if the circumstances have changed and their reclusion is no longer required, States have the obligation to release children, even when they have not completed the sentence established in each specific case. To this end, States must provide early release programs in their legislation. On this point, the Committee on the Rights of the Child, based on article 25 of the Convention on the Rights of the Child, which provides for the periodic review of measures involving the deprivation of liberty, has established that “the possibility of release should be realistic and regularly considered.” 234 163. Based on the above, and in light of the best interests of the child as an interpretative principle designed to ensure the maximum satisfaction of the child’s rights (supra para. 143), life imprisonment and reclusion for life for children are incompatible with Article 7(3) of the American Convention, because they are not exceptional punishments, they do not the Federal Capital based its verdict, corresponding to cases No. 833/838/839/851/910/920/937/972/1069 against Dante Núñez, Claudio David Núñez and Lucas Matías Mendoza, of April 12, 1999 (file of annexes to the submission of the case, tome VIII, folios 4638 and 4639). 231 The judgment indicates that “[t]hese parameters for graduating the punishment lead to finding it just to impose on César Alberto Mendoza the punishment of life imprisonment, loss of civil rights, and costs […].” Cf. Explanatory statement of the factual and legal grounds on which Juvenile Oral Court No. 1 of the Federal Capital based its verdict in case No. 1,084 against Guillermo Antonio Álvarez and César Alberto Mendoza (file of annexes to the pleadings and motions brief, tome XII, folio 6764). 232 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. 90. 233 Rule 5.1 of the United Nations Standard Minimum Rules for the Administration of Juvenile Justice ("The Beijing Rules") indicates that: “[t]he juvenile justice system shall emphasize the well-being of the juvenile and shall ensure that any reaction to juvenile offenders shall always be in proportion to the circumstances of both the offenders and the offence.” While, Rule 17.1(a) indicates that: “[t]he reaction taken shall always be in proportion not only to the circumstances and the gravity of the offence but also to the circumstances and the needs of the juvenile as well as to the needs of the society.” 234 Committee on the Rights of the Child, General Comment No. 10, Children’s rights in juvenile justice, CRC/C/GC/10, 25 April 2007, para. 77. 56