GÜLEÇ JUDGMENT OF 27 JULY 1998 35 ideological outlook and a complete lack of objectivity”, scarcely reflected an objective attitude and a determination to investigate the accusations against the gendarmes seriously. Analysing a number of aspects of the way in which the investigation was conducted in the present case, the Commission noted several serious shortcomings and expressed the opinion that Article 2 had been breached as regards its procedural implications also. 2. The Court’s assessment 77. The general legal prohibition of arbitrary killing by the agents of the State laid down in Article 2 would be ineffective, in practice, if there existed no procedure for reviewing the lawfulness of the use of lethal force by State authorities. The obligation to protect the right to life under this provision, read in conjunction with the State’s general duty under Article 1 of the Convention to “secure to everyone within [its] jurisdiction the rights and freedoms defined in [the] Convention”, requires by implication that there should be some form of effective official investigation when individuals have been killed as a result of the use of force by, inter alios, agents of the State (see the McCann and Others v. the United Kingdom judgment of 27 September 1995, Series A no. 324, p. 50, § 169, and the Kaya judgment cited above, p. 324, § 86). 78. The procedural protection for the right to life inherent in Article 2 of the Convention means that agents of the State must be accountable for their use of lethal force; their actions must be subjected to some form of independent and public scrutiny capable of determining whether the force used was or was not justified in a particular set of circumstances (see, most recently, the Kaya judgment cited above, p. 324, § 87). 79. The Court observes that the Government blamed the PKK for Ahmet Güleç’s death. In the first place, the report on the incidents drawn up by the commanding officers of the gendarmerie, the İdil police and the army indicates that the security forces were convinced that this death was the result of a “shot fired by armed troublemakers who had mingled with the demonstrators” (see paragraph 17 above). Similarly, in its letter of 14 June 1991 replying to the İdil District Commissioner’s letter of 12 June, the gendarmerie asserted without any reservation that the demonstration had been “organised by terrorist militants from the PKK” and that “the infiltration of armed militants among the people and the use of weapons during the demonstration show how serious the situation was” (see paragraph 23 above). This same document also reveals the lack of cooperation by the gendarmerie, which announced that it could not supply the names of the soldiers who had been on board the armoured vehicle.