GIULIANI AND GAGGIO v. ITALY JUDGMENT 83 examinations because of the cremation of the body (see paragraph 264 above). 315. The Court accepts that giving notice of an autopsy scarcely three hours before the beginning of the examination (see paragraph 48 above) may make it difficult in practice, if not impossible, for injured parties to exercise their power to appoint an expert of their choosing and secure the latter's attendance at the forensic examinations. The fact remains, however, that Article 2 does not require, as such, that the victim's relatives be afforded this possibility. 316. It is also true that, where an expert medical examination is of crucial importance in determining the circumstances of a death, significant shortcomings in the conduct of that examination may amount to serious failings capable of undermining the effectiveness of the domestic investigation. The Court reached that conclusion, in particular, in a case where, following allegations that the death had been the result of torture, the autopsy report, signed by doctors who were not forensic specialists, had failed to answer some fundamental questions (see Tanlı, cited above, §§ 149-154). 317. The present case, however, differs significantly from Tanlı. Moreover, the applicants did not provide evidence of any serious failings in the autopsy performed on Carlo Giuliani. It was not alleged, either, that the forensic experts had failed to establish the cause of death with certainty; the applicants did not contest before the Court the domestic authorities' conclusion that Carlo Giuliani had died as a result of the shot fired by M.P. 318. The applicants stressed that the forensic experts had omitted to extract and record a fragment of bullet which, according to the results of the scan performed on the body, was lodged in the victim's head (see paragraph 266 above). The Court notes that Mr Salvi, one of the experts, explained at the “trial of the twenty-five” that the fragment had been very small and very difficult to find because of the damage to the brain tissue and the large amount of blood present. It had been regarded as a “minor detail” and the search for it had been discontinued (see paragraph 130 above). 319. The Court does not consider it necessary to assess the pertinence of this explanation. For the purposes of examining the applicants' complaint, it simply observes that the fragment in question might have served to shed light on the trajectory of the fatal bullet (and in particular whether it had been deflected by another object before hitting Carlo Giuliani). However, as the Court has just noted in relation to the substantive aspect of Article 2 (see paragraphs 192-193 above), the use of force would have been justified under this provision even if the “intermediate object theory” had been dismissed. It follows that the metal fragment in question was not crucial to the effectiveness of the investigation. Moreover, the Court observes that the cremation of Carlo Giuliani's body, which made any further expert medical

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