on protestors in the Mustafa Mahmoud Park, along with approximately thirty other deaths. The Complainants allege that these deaths were caused by the disproportionate and deliberate use of force by riot police on unarmed civilians. They further allege that the riot police are agents of the State and that as such the State is responsible for their actions. They argue that legal authority is required for an agent of the State to use force against a person, and allege that no such legal authority had been suggested by the Respondent State. The Complainants argue that such legal authority can also not be implied, since there is no evidence that the people in the park constituted any threat to the police officers or public safety, and furthermore that the Victims were initially told that the level of police presence was to protect them from assault by others. 94. The Complainants submit that the level of force employed by the riot police was plainly excessive and disproportionate, that there is no justification for it in national or international law and that it contravenes international standards on the use of force which require force to be used only as a last resort, to the minimum extent necessary, proportionate to the threat posed and designed to avoid unwarranted pain or injury. 95. Regarding the second part of the right to life, namely to take measures to protect life and prevent violations, the Complainants argue that law enforcement operations must be planned and carried out in a manner which “limits the danger of recourse to the use of force.” The Complainants allege that there is no evidence that the police operation was planned with a view to minimizing incidental loss of life. As justification for this point the Complainants submit that the size of the force used, the degree of force used and the failure to give any prior opportunity to allow people in the park to disperse, including in some cases preventing them from doing so, is not compatible with the standard of care perquisite in an operation concerning an unarmed and predominantly peaceful crowd comprising men, women and children. The Complainants argue that the fact that six of the Victims were beaten and assaulted illustrates the deliberate and excessive use of force which was not minimized to any extent. 96. Regarding the third part of the right to life, namely the thorough, prompt and impartial investigation of allegations of violations of the right to life, the Complainants argue that this requires an adequate and effective investigation 23

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