36 184. As the Court has repeatedly asserted in its case-law that "compliance with the duties imposed by Article 4 of the American Convention, in conjunction with Article 1(1) thereof, does not only presuppose that no person can be arbitrarily deprived of his life (negative duty) but also requires, pursuant to its obligation to guarantee the full and free exercise of human rights, that the States adopt any and all necessary measures to protect and preserve the right to life (positive duty) of the individuals under 240 their jurisdiction." Thus the Court held: 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 241 jurisdiction. 185. The Commission considers it necessary to remind at this point the relevant international standards on the use of force by state security bodies. 186. The IACHR has indicated that even when the State has the right and the obligation to offer protection against threats -and thus may use lethal force on certain occasions- this capacity must be restricted to cases of strict necessity and proportionality. If it does not correspond to these principles, the lethal use of force may constitute an arbitrary deprivation of life or a summary execution. This is the same as saying that the lethal use of force must necessarily be justified by the right of the State to protect .242 everyone's security 187. The Commission has also emphasized that the use of force may be justified, for example, in self-defense, or by the need to neutralize or disarm individuals involved in an armed confrontation. Nevertheless, if someone loses their life as a result of the excessive or disproportionate use of force on the part officials charged with upholding the law, this fact would equate to an arbitrary deprivation of 243 life. 188. In this respect, the Court has established that the use of force must be defined as exceptional, and must be planned and proportionally limited by the authorities. In this sense, the Court has made it clear that the use of force, or tools of control, may only be justified when all other means of 244 control have been tried, and have failed. 189. According to the Court, the lethal use of force and firearms by state security agents against individuals, which must be prohibited as a general rule, is within higher level of exceptionality. Its exceptional use must be set out by law, and be interpreted strictly in a way so as be minimized, being no 245 more than an "absolute necessity" in relation to the force or threat that it seeks to confront. When 246 excessive force is used, all resulting loss of life is arbitrary. 240 I/A Court HR, Case Zambrano Vélez and others Vs. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166. paragraph 80; I/A Court HR, Case of the “Street Children” (Villagrán Morales and others). Judgment of November 19, 1999. Series C No. 63. paragraph 144. 241 I/A Court HR, Case Zambrano Vélez and others Vs. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166, paragraph 81; I/A Court HR, Case Montero Aranguren and others (Retén de Catia). Judgment of July 5, 2006. Series C No. 150. paragraph 66. 242 IACHR. Report on Terrorism and Human Rights, paragraph 88. 243 IACHR, Case 10559, Chumbivilcas vs. Peru, Report 1/96, March 1, 1996; IACHR, Case 11291, Carandiru v. Brazil, Report 34/00, April 13, 2000, paragraphs 63, 67, 91. 244 I/A Court HR, Case Montero Aranguren and others (Retén de Catia). Judgment of July 5, 2006. Series C No. 150. paragraph 67. 245 I/A Court HR, Case Montero Aranguren and others (Retén de Catia). Judgment of July 5, 2006. Series C No. 150. paragraph 68. In a similar sense, see: ECHR, Huohvanainen v. Finland, 13 March 2007, no. 57389/00, paragraphs 93-94,; ECHR, Erdogan and Others v. Turkey, 25 April 2006, no. 19807/92, paragraph 67; ECHR, Kakoulli v. Turkey, 22 November 2005, no. 38595/97, paragraphs 107-108; ECHR, McCann and Others v. the United Kingdom, judgment of 27 September 1995, Series A no. Continues…