68 GIULIANI AND GAGGIO v. ITALY JUDGMENT dangerous. Furthermore, when the move was made, there was no reason to suppose that the demonstrators would be able to force the carabinieri, as they did, to withdraw rapidly and in disorderly fashion, thereby prompting the jeeps to retreat in reverse gear and leading to one of them becoming hemmed in. The immediate cause of these events was the violent and unlawful attack by the demonstrators. It is quite clear that no operational decision previously taken by the law-enforcement agencies could have taken account of this unforeseeable element. Moreover, the fact that the communications system chosen apparently only allowed information to be exchanged between the police and carabinieri control centres, but not direct radio contact between the police officers and carabinieri themselves (see paragraph 222 above), is not in itself sufficient basis for finding that there was no clear chain of command, a factor which, according to the Court's case-law, is liable to increase the risk of some police officers shooting erratically (see Makaratzis, cited above, § 68). M.P. was subject to the orders and instructions of his superior officers, who were present on the ground. 260. Moreover, the Court does not see why the fact that M.P. was injured and deemed unfit to remain on duty should have led those in command to take his weapon from him. The weapon was an appropriate means of personal defence with which to counter a possible violent and sudden attack posing an imminent and serious threat to life, and was indeed used for that precise purpose. 261. Lastly, as regards the events following the fatal shooting (see paragraph 229 above), the Court observes that there is no evidence that the assistance afforded to Carlo Giuliani was inadequate or delayed or that the jeep drove over his body intentionally. In any case, as demonstrated by the autopsy report (see paragraph 50 above), the brain injuries sustained as a result of the shot fired by M.P. were so severe that they resulted in death within a few minutes. 262. It follows that the Italian authorities did not fail in their obligation to do all that could reasonably be expected of them to provide the level of safeguards required during operations potentially involving the use of lethal force. There has therefore been no violation of Article 2 of the Convention on account of the organisation and planning of the policing operations during the G8 summit in Genoa and the tragic events on Piazza Alimonda. II. ALLEGED VIOLATION OF ARTICLE 2 OF THE CONVENTION IN ITS PROCEDURAL ASPECT 263. The applicants alleged that the respondent State had failed in several respects to comply with the procedural obligations arising out of Article 2 of the Convention. The Government contested that allegation.

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