56 GIULIANI AND GAGGIO v. ITALY JUDGMENT law-enforcement agencies had at no point been ordered to fire and their equipment had been intended for their personal protection. 207. No specific provisions concerning the use of firearms had been adopted with a view to the G8 summit, but the circulars issued by the senior command of the carabinieri had referred to the provisions of the CC. 3. The Court's assessment (a) General principles 208. Article 2 § 1 enjoins the State not only to refrain from the intentional and unlawful taking of life, but also to take appropriate steps to safeguard the lives of those within its jurisdiction (see L.C.B. v. the United Kingdom, 9 June 1998, § 36, Reports 1998-III, and Osman v. the United Kingdom, 28 October 1998, § 115, Reports 1998-VIII). 209. The primary duty on the State to secure the right to life entails, in particular, putting in place an appropriate legal and administrative framework defining the limited circumstances in which law enforcement officials may use force and firearms, in the light of the relevant international standards (see Makaratzis v. Greece [GC], no. 50385/99, §§ 57-59, ECHR 2004-XI, and Bakan, cited above, § 49; see also the relevant paragraphs of the UN Principles, paragraph 154 above). In line with the principle of strict proportionality inherent in Article 2 (see paragraph 176 above), the national legal framework must make recourse to firearms dependent on a careful assessment of the situation (see, mutatis mutandis, Nachova and Others, cited above, § 96). Furthermore, the national law regulating policing operations must secure a system of adequate and effective safeguards against arbitrariness and abuse of force and even against avoidable accident (see Makaratzis, cited above, § 58). 210. Applying these principles, the Court has, for instance, characterised as deficient the Bulgarian legal framework which permitted the police to fire on any fugitive member of the armed forces who did not surrender immediately in response to an oral warning and the firing of a warning shot in the air, without containing any clear safeguards to prevent the arbitrary deprivation of life (see Nachova and Others, cited above, §§ 99-102). The Court also identified deficiencies in the Turkish legal framework, adopted in 1934, which listed a wide range of situations in which a police officer could use firearms without being liable for the consequences (see Erdoğan and Others v. Turkey, no. 19807/92, §§ 77-78, 25 April 2006). On the other hand, it held that a regulation setting out an exhaustive list of situations in which gendarmes could make use of firearms was compatible with the Convention. The regulation specified that the use of firearms should only be envisaged as a last resort and had to be preceded by warning shots, before shots were fired at the legs or indiscriminately (see Bakan, cited above, § 51).