inflicted on the Nigeria Nation especially in the North East, However, a situation where a group of Citizens of a State can be styled as members of a Terrorist Group (without any conclusive evidence) and shot portends danger for the society at large. This needs to be discouraged. As earlier noted, apart from the substantive right to life in International Human Rights Law, the procedural aspect is equally important. International law imposes a duty on a State to carry out independent investigation into killings in the circumstances that it is likely to be extra- judicial. After the killings in this case, no further action was taken by the Defendant; this is unfortunate to say the least. Even if the State is not guilty of substantive violation of the right to life, it can still be liable for failure to investigate. Accordingly, as the European Court of Human Rights stated in MAKARATEIS Vs. GREECE (2004) ECHR 5038/99 the national law regulating policing operation must put on ground a system of adequate and effective safeguards against arbitrariness and abuse of force even against avoidable accident. Thus, the obligation to protect life, read together with the State’s general duty under Article 4 of the Charter (Equivalent to Article 4 of the African Charter on Human and People’s Rights) (words in Parenthesis is ours) 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 (see CAKACI Vs. TURKEY (1999) ECHR 2365/94. The essential purpose of such an investigation is to ensure the effective implementation of domestic laws safeguarding the right to life, in those cases involving State agents or bodies, to ensure their accountability for deaths 46