28 […] whenever the use of force [by state agents results in the death or injuries to one or more individuals, the State has the obligation to give a satisfactory and convincing explanation of the 144 events and to rebut allegations over its liability through appropriate evidentiary elements. 124. Similarly, Article 3 of the United Nations Code of Conduct for Law Enforcement Officials stipulates that: “Law enforcement officials may use force only when strictly necessary and to the extent 145 required for the performance of their duty;” and Principle 4 of the “Basic Principles on the Use of Force 146 and Firearms by Law Enforcement Officials” indicates that “[l]aw enforcement officials, in carrying out their duty, shall, as far as possible, apply non-violent means before resorting to the use of force or firearms. They may use force and firearms only if other means remain ineffective or without any promise of achieving the intended result.” 125. As a result, the law must determine when State security agents may use lethal force, interpreting its use restrictively, that is, only when it is absolutely necessary in relation to the force or 147 threat to be repelled. Clearly, “state agents must distinguish between persons who, by their actions, constitute an imminent threat of death or serious injury and persons who do not present such a threat, 148 and use force only against the former.” 126. In this sense, the IACHR deems it important to recall that: […] States must not use force against individuals who no longer present a threat […], such as individuals who have been apprehended by authorities, have surrendered, or who are wounded and abstain from hostile acts […] The use of lethal force in such a manner would constitute extrajudicial killings in flagrant violation of Article 4 of the Convention and Article I of the 149150 Declaration. 144 Inter-Am. Ct. H.R., Case of Zambrano Vélez et al v. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166, para. 108; Inter-Am. Ct. H.R., Case of Montero Aranguren et al (Detention Center of Catia), Judgment of July 5, 2006. Series C No. 150, para. 80; Inter-Am. Ct. H.R., Case of Baldeón García. Judgment of April 6, 2006. Series C No. 147, para. 120. 145 U.N. doc. A/34/46 (1979), G.A. res. 34/169. 146 Adopted by the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, Cuba, August 27 to September 7, 1990. 147 Inter-Am. Ct. H.R., Case of Zambrano Vélez et al v. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166, para. 84; Inter-Am. Ct. H.R., Case of Montero Aranguren et al (Detention Center of Catia). Judgment of July 5, 2006. Series C No. 150, para. 68. In a similar sense, 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, Resolution 34/169, of December 17, 1979, Article 3; According to Principle 11 of the “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, held in Havana (Cuba) from August 27 to September 7, 1990, the rules and regulations on the use of firearms by law enforcement officials should contain clear guidelines that: a) Specify the circumstances under which law enforcement officials are authorized to carry firearms and prescribe the types of firearms and ammunition permitted; b) Ensure that firearms are used only in appropriate circumstances and in a manner likely to decrease the risk of unnecessary harm; c) Prohibit the use of those firearms and ammunition that cause unwarranted injury or present an unwarranted risk; d) Regulate the control, storage and issuing of firearms, including procedures for ensuring that law enforcement officials are accountable for the firearms and ammunition issued to them; e) Provide for warnings to be given, if appropriate, when firearms are to be discharged; f) Provide for a system of reporting whenever law enforcement officials use firearms in the performance of their duty. 148 Inter-Am. Ct. H.R., Case of Zambrano Vélez et al v. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166, para. 85; in a similar sense, IACHR. Report on Terrorism and Human Rights 2002. 149 IACHR, Report on Terrorism and Human Rights, OEA/Ser.L/V/ll.116, Doc. 5 rev. 1 corr., October 22, 2002, para. 91. See also, Case of Arturo Ribón Avila, paras. 159 on; Case of Bustios Saavedra, paras. 58-63; Case of Carandiru, paras. 63, 67 and 91. 150 Inter-Am. Ct. H.R., Case of Zambrano Vélez et al v. Ecuador. Merits, Reparations and Costs. Judgment of July 4, 2007. Series C No. 166, para. 85.