24 necessary measures to protect and preserve the right to life (positive duty) of the individuals under their jurisdiction64. 81. Based on the foregoing, States must adopt all necessary measures to create a legal framework that deters any possible threat to the right to life; establish an effective legal system to investigate, punish, and redress deprivation of life by State officials or private individuals; and guarantee the right to unimpeded access to conditions for a dignified life. Especially, States must see that their security forces, which are entitled to use legitimate force, respect the right to life of the individuals under their jurisdiction65. * * * 82. The Court has had the opportunity, in other cases, to decide on the criteria which determine the legitimate use of force by governmental security forces. The facts of the present case are analyzed in light of those criteria: 1) Exceptionality, necessity, proportionality and humanity 83. The use of force by law enforcement officials must be defined by exceptionality and must be planned and proportionally limited by the authorities. As such, the Tribunal has considered that force or coercive means can only be used once all other methods of control have been exhausted and have failed66. 84. The use of lethal force and firearms against individuals by law enforcement officials – which must be forbidden as a general rule – 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 circumstances and never exceed the use which is "absolutely necessary" in relation to the force or threat to be repealed67. When excessive force is used, any resulting deprivation of life is arbitrary68. 85. The use of force must be limited by the principles of proportionality, necessity and humanity. Excessive or disproportionate use of force by law enforcement officials that result in the loss of life may therefore amount to arbitrary deprivations of life. The principle of necessity justifies only those measures of military violence which are not forbidden by international law and which are relevant and proportionate to ensure the prompt subjugation of the enemy with the least possible cost of human and economic resources. The principle of humanity complements and inherently Cf. Case of the “Street Children” (Villagrán Morales et al.), supra note 59, para. 144. See also Case of Miguel Castro-Castro Prison, supra note 14, para. 238, and Case of Vargas-Areco. Judgment of September 26, 2006. Series C No. 155, para. 14. 64 65 Cf. Case of Montero Aranguren et al. (Detention center of Catia), supra note 31, para. 66. See also Case of Miguel Castro-Castro Prison, supra note 14, para. 238, and Case of Servellón-García et al., supra note 14, para. 102. 66 Cf. Case of Montero Aranguren et al. (Detention center of Catia), supra note 31, para. 67. 67 Cf. Case of Montero Aranguren et al. (Detention center of Catia), supra note 31, para. 68. Similarly, see also ECHR, Huohvanainen v. Finland, 13 March 2007, no. 57389/00, paras. 93-94,; ECHR, Erdogan and Others v. Turkey, 25 April 2006, no. 19807/92, para. 67; ECHR, Kakoulli v. Turkey, 22 November 2005, no. 38595/97, paras. 107-108; ECHR, McCann and Others v. the United Kingdom, judgment of 27 September 1995, Series A no. 324, paras. 148-150, 194, and Code of Conduct for Law Enforcement Officials adopted by the United Nations General Assembly, Order 34/169 of December 17, 1979, Article 3. 68 Case of Montero Aranguren et al. (Detention center of Catia), supra note 31, para. 68. See also the Basic Principles on the Use of Force and Firearms by Law Enforcement Officials, adopted by the Eight Congress of the United Nations for the Prevention of Crime and the Treatment of Criminals, Havana, Cuba, August 27 - September 7, 1990, Principle 9.