Thus, the legality of a killing outside the context of armed conflict (as in this case) is governed by human rights standards especially the ones concerning the use of force. Sometimes referred to as “law enforcement model”, they do not in fact apply only to armed forces or in time of peace. They apply to all government officials who exercise police powers including the military and Security forces operating in contexts where violence exist but falls short of the threshold of armed conflict. Lethal force under human rights law is legal if it is strictly and directly necessary to save life. Thus, the defense of self-defense and necessity (as purportedly claimed by the Defendant in this case) must be circumscribed within the limits of force required by human rights law. Questions of due diligence, reasonableness, and proportionality, the use of warnings, restraint and capture are all matters to be considered in this regard. In McCann Vs. UK (1995) ECHR 18984/91 at paragraph 150, the European Court of Human Rights in dealing with the deprivation of life contrary to Article 2 of the European Convention which is similar to the provisions of Article 4 of the African Charter, which stressed that the Court must subject allegations of breach of Article 2 of the Convention to the most careful scrutiny and that in cases concerning the use of force by State agents , it must take into consideration not only the actions of the agents of the State who actually administered the force but also all the surrounding circumstances including such matters as relevant regulatory framework in place and the planning and control of the actions under examination. See also Makarat 215 Vs. Greece (2004) ECHR 5038/99 at Patas 5759. That indeed appears to be the international minimum standard regarding the use of lethal force. The United Nations Basic Principles on the use of Force and Firearms by Law Enforcement Officials adopted on 7th September, 1990 by the 8th United Nations Congress on the Prevention of Crime and Treatment of Offenders provides in paragraph 9 as follows: “Law enforcement officials shall not use firearms against persons except in self- defense or defense of others, against the imminent threat of death or serious injury, to prevent the perpetration of a particular serious crime involving grave threat to life, to arrest a person presenting such a danger and resisting their authority, or to prevent his or her escape, and only when less extreme means are insufficient to achieve these objectives. In any event 41