iv. Proportionality: Proportionality requires that there is a reasonable relationship between the means employed and the aims to be achieved. All these factors may not all exist or be considered necessary in all circumstances. With regard to right to life (the principal subject matter of the suit under consideration), international human rights provisions relating to the right to life must be strictly construed. This is particularly in cases where excessive use of force is used by law enforcement agencies. The right to life should be understood as creating two obligations, namely, a substantive obligation in relation to the guarantee of life itself; and the procedural obligation, where there has been a loss of life. The United Nations Human Rights Committee, in a long line of cases, which cannot be captured here for lack of space, has addressed the relationship between the right to life and armed conflict and has noted the link between non- compliance with international law rules prohibiting resort to armed force and loss of innocent lives. First, a State has a responsibility to ensure that the law protects everyone’s life. This includes a procedural aspect whereby the circumstances of deprivation of life receives public and independent scrutiny. Second, a State has obligation to investigate deaths irrespective of how the authorities found about the death whether State authorities were involved or circumstances surrounding the death. This responsibility is not diminished in the counter- terrorism context. Failure to investigate properly a death will be at odds with a State procedural obligations in relation to the right to life and this will be in addition to any violation found in relation to the killing itself. These are therefore the two aspects to the right of life. We have analyzed the principles of international law regarding the protection of human rights, even in the situation of counter –terrorism, in order to make reasoned findings(s) with regard to the case at hand. As earlier noted, the Applicants’ primary contention as a basis for their claim is that the security agents of the Defendant failed to use reasonable force in the execution of the operation of 20th September, 2013 which led to the death of eight 39