20 ANGUELOVA v. BULGARIA JUDGMENT 2. Deprivation of life shall not be regarded as inflicted in contravention of this Article when it results from the use of force which is no more than absolutely necessary: (a) in defence of any person from unlawful violence; (b) in order to effect a lawful arrest or to prevent the escape of a person lawfully detained; (c) in action lawfully taken for the purpose of quelling a riot or insurrection.” A. Whether Mr Zabchekov died as a result of ill-treatment while in police custody 1. The parties' submissions (a) The applicant 103. The applicant submitted that the Government's explanation, which was based on two main arguments – that the fatal skull injury had been sustained long before Mr Zabchekov's arrest and that the remaining injuries on his body had been received during the chase – was implausible as it did not accord with the evidence. 104. As regards the skull injury, the applicant asserted that the conclusions of the second forensic report had been highly suspect as they had deviated from the findings of the first forensic report without any explanation. The authorities had been quick to rely on the second report, ignoring the contradictions. The second report's conclusion as to the timing of the fatal injury had been based only on the shape of the blood clot as seen on photographic images taken almost six hours after the time of death. The suggestion that the skull injury had been inflicted ten hours before Mr Zabchekov's death, at about 6.45 p.m. on 28 January 1996, was, in the applicant's submission, incompatible with the evidence and highly unrealistic. The occurrence of an injury serious enough to eventually cause death could not have gone completely unnoticed by so many persons who had talked to Mr Zabchekov at length and observed him. Furthermore, the Government had not offered any serious evidence in support of their implied theory that Mr Zabchekov's alleged “permanent, chronic, neurotic condition” had increased the chances that the fatal injury had been caused by “falling on a ... broad, even surface”. The Government's explanation of the other injuries found on Mr Zabchekov's body – on his chest, face and right wrist – was clearly implausible in the applicant's view. Such injuries could not be inflicted by falling to the ground while running or by the normal use of handcuffs. Indeed, the origin of those injuries had never been investigated and the