GIULIANI AND GAGGIO v. ITALY JUDGMENT – SEPARATE OPINIONS 101 (see paragraph 194 of the judgment). Accordingly, it considers it unnecessary to examine whether the use of force was also unavoidable “in action lawfully taken for the purpose of quelling a riot or insurrection” within the meaning of sub-paragraph (c) of the second paragraph of Article 2 (see paragraph 196 of the judgment). However, that was precisely the crucial issue to be examined in this case. 16. These considerations lead us to the conclusion that there has been a violation of Article 2 of the Convention in its substantive aspect.