violation of subparagraphs 2 to 7 of Article 7 of the Convention necessarily entails the violation of Article 7(1) thereof. 100 80. Furthermore, the Court has held that security should also be understood as protection against all unlawful or arbitrary interference with physical liberty. 101 Likewise, the protection of liberty safeguards both an individual’s physical liberty and his or her personal safety, in a context in which the lack of guarantees may undermine the rule of law and deprive detainees of the basic forms of legal protection. 102 For its part, the European Court of Human Rights has declared that the right to personal security implies protection of physical liberty. 103 In turn, the United Nations Human Rights Committee has pointed out that the right to security cannot be construed in a restrictive way, which implies that the State cannot ignore threats to the life of persons who are arrested or otherwise detained. 104 81. The facts of this case occurred in a context of a heavy military presence in the state of Guerrero in the 1990s, 105 as an official response to drug trafficking and to emerging armed groups such as the “Ejército Zapatista de Liberación Nacional” (Zapatista National Liberation Army) (EZLN) and the “Ejército Popular Revolucionario” (Popular Revolutionary Army) (EPR). 106 This response involved the deployment of armed forces in the states where these groups operated and where drug trafficking activities took place. 107 Consequently, and taking into account some of the disputes between the parties (infra paras. 90 to 92), the Court deems it relevant to explain the scope of some of the treaty obligations under such circumstances. 82. In the abovementioned context, during that decade, the Armed Forces took on public security roles and tasks in some states, including Guerrero, patrolling highways and roads, setting up roadblocks, occupying towns, arresting and interrogating people and searching homes in search of uniforms, weapons and 100 Cf. Case of Chaparro Álvarez and Lapo Íñiguez. v. Ecuador, supra note 99, para. 54; Case of Barreto Leiva v. Venezuela. Merits, Reparations and Costs. Judgment of November 17, 2009. Series C N° 206, para. 116; Case of Usón Ramírez v. Venezuela, supra note 99, para. 143. 101 Cf. Case of Chaparro Álvarez and Lapo Íñiguez. v. Ecuador, supra note 99, para. 53. 102 Case of the “Street Children” (Villagrán Morales et al) v. Guatemala; supra note 29, para. 135; Case of Acosta Calderón v. Ecuador. Merits, Reparations and Costs. Judgment of June 24, 2005. Series C N° 129, para. 56; Case of García Asto and Ramírez Rojas v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 25, 2005. Series C N° 137, para. 104. 103 41. Cf. ECHR, Case of Affaire Villa v. Italy, Judgment of 20 April 2010, App. No. 19675/06, para. 104 According to the Committee, Article 3 of the Universal Declaration of Human Rights refers to the individual’s right to life, to liberty and to security. These elements are addressed in separate clauses in the text. Although the International Covenant on Civil and Political Rights only refers to the right to security in Article 9, there is no evidence that it was intended to limit the concept of the right to security solely to situations of deprivation of liberty. Thus, the Committee concludes that “[A]n interpretation of Article 9 which would allow a State party to ignore threats to the personal security of persons not detained or imprisoned within its jurisdiction would render the guarantees of the Covenant totally ineffective.” Cf. United Nations. Committee on Human Rights. Case of Delgado Paez V. Colombia. Communication N° 195/1985 of July 12, 1990, para. 5.5 and Case of Chongwe V. Zambia, Communication Nº 821/1998 of October 25, 2000, para. 5.3. 105 Case of Rosendo Cantú et al. v. Mexico, supra note 30, para. 70. 106 Cf. Affidavit of Miguel Carbonell Sanchez of March 30, 2010 (Merits file, volume III, page 1166) and Human Rights Watch. Uniformed Impunity: The inadequate use of justice in Mexico to investigate abuses committed during anti-drug trafficking and public security operations (Impunidad Uniformada: uso indebido de la justicia en Mexico para investigar abusos cometidos durante operativos contra narcotrafico y de seguridad publica), April 2009 (File of attachments to the brief of pleadings and motions, volume XXI, page 8675 to 8676). 107 Cf. Affidavit rendered by Miguel Carbonell Sanchez, supra note 106, page 1166 and Affidavit rendered by Jose Luis Piñeyro on August 9, 2010 (record of the merits, volume III, pages 1284 to 1294). 31