security, whether they are members of its police forces or its armed forces.69 Accordingly, the Court has also held that States must adopt the necessary measures, not only at the legislative, administrative and judicial level, by issuing penal standards and establishing a justice system to prevent, eliminate and punish the deprivation of life as a result of criminal acts, but also to prevent and protect individuals from the criminal acts of other individuals and investigate these situations effectively. 70 The Court has also established that, along with the right to life, the right to personal integrity not only means that the State must respect this right (negative obligation), but that it must take all appropriate measures to guarantee it (positive obligation), in compliance with the general obligation in Article 1(1) of the American Convention.71 123. The Court has also indicated that, in addition to the general obligations to respect and guarantee the rights enshrined in Article 1(1) of the Convention, there are special duties that derive form these, which are determined on the basis of the particular needs for protection of the individual holder of the right, either owing to his personal situation or to the specific situation in which he finds himself.72 124. Furthermore, the Court has established that in certain contexts, the work undertaken by human rights defenders can place them in a special situation of vulnerability, against which the State must take all necessary and reasonable measures to ensure their right to life, personal liberty and personal safety.73 In this regard, it has emphasized that States have a duty to create the necessary conditions for the effective enjoyment of the rights established in the Convention, since compliance with this obligation is tied intrinsically to the protection and recognition of the importance of the role of human rights defenders, whose work is essential to strengthen democracy and the rule of law.74 Likewise, it has stated75 that the obligation to protect human rights defenders has been recognized by the Organization of American States,76 as well as in other international instruments.77 69 Cf. Case of Juan Humberto Sánchez v. Honduras. Preliminary Objection, Merits, Reparations and Costs Judgment of June 7, 2003. Series C No. 99, para. 110, and Case of Penal Miguel Castro Castro v. Peru. Merits, Reparations and Costs Judgment of November 25, 2006. Series C No. 160, para. 237. 70 Cf. Case of the Massacre of Pueblo Bello v. Colombia, supra, para. 120, and Case of the Massacres of Ituango v. Colombia. Preliminary Objection, Merits, Reparations and Costs Judgment of July 1, 2006. Series C No. 148, para. 131. Similarly, Case of Servellón García et al. v. Honduras. Merits, Reparations and Costs. Judgment of September 21, 2006. Series C No. 152, para. 98. 71 Cf. Case of Vera Vera et al. v. Ecuador. Preliminary Objection, Merits, Reparations and Costs Judgment of May 19, 2011. Series C No. 226, para. 41. 72 Cf. Case of the Massacre of Pueblo Bello v. Colombia, supra, para. 111, and Case of Furlan and Relatives v. Argentina. Preliminary Objections, Merits, Reparations and Costs Judgment of August 31, 2012. Series C No. 246, para. 134. 73 Cf. Case of Valle Jaramillo et al. v. Colombia, supra, paras. 81 to 91, and Case of Fleury et al. v. Haiti. Merits and Reparations. Judgment of November 23, 2011. Series C No. 236, paras. 79 to 82. 74 Cf. Case of Valle Jaramillo et al. v. Colombia, supra, para. 87, and Case of Fleury et al. v. Haiti, supra, para. 80. 75 Cf. Case of Valle Jaramillo et al. v. Colombia, supra, para. 89 and footnote 48, and Case of Fleury et al. v. Haiti, supra, para. 80 and footnote 66. 76 Cf. Organization of American States, “Human Rights Defenders in the Americas: Support for the individuals, groups and organizations of civil society working to promote and protect human rights in the Americas,” AG/Res. 1671 (XXIX-0/99) of June 7, 1999; AG/Res. 1711 (XXX-0/00) June 5, 2000, and AG/Res. 2412 (XXXVIII-0/08) of June 3, 2008. 77 For example, Article 1 of the Declaration on the Right and Responsibility of Individuals, Groups and 31