I. GENERAL CONSIDERATIONS A. State duty to protect Both the universal and regional systems emphasize that States have a duty to protect those living within their jurisdictions from terrorism, while cautioning that this does not imply an absence of limits to the exercise of State power. United Nations In the case Delgado Paez v. Colombia, in which the author of a petition to the Human Rights Committee had received death threats, the Committee considered the question of States’ duty to protect persons under their jurisdiction: Although in the [International Covenant on Civil and Political Rights] (hereafter, the Covenant), the only reference to the right of security of person is to be found in article 9, there is no evidence that [this] was intended to narrow the concept of the right to security only to situations of formal deprivation of liberty…. States parties have undertaken to guarantee the rights enshrined in the Covenant. It cannot be the case that, as a matter of law, States can ignore known threats to the life of persons under their jurisdiction, just because he or she is not arrested or otherwise detained. States parties are under an obligation to take reasonable and appropriate measures to protect them. An interpretation of article 9 which would allow a State party to ignore threats to the personal security of non-detained persons within its jurisdiction would render totally ineffective the guarantees of the Covenant. --Delgado Paez v. Colombia, Case No. 195/1985, Views adopted on 12 July 1990. ***** The Committee [on the Elimination of Discrimination Against Women] calls upon the Government to protect women in accordance with the provision of the Constitution that states that the State is responsible for the safety of persons and property. The Committee recommends that better care be taken of all women and girls who are victims of terrorist violence. -- A/54/38, para. 78 (1995). European Court of Human Rights The Court recalls that the first sentence of Article 2 § 1 [of the European Convention for the Protection of Human Rights and Fundamental Freedoms] (hereafter, the Convention) 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.... This involves a primary duty on the State to secure the right to life by putting in place effective criminal- 11