time to the occupants to surrender. This is in view of the fact that there is no evidence of self – defense. The Defendant alleged that before the raid on the building on the 20th of September, 2013, there was security report indicating a plan by the Boko Haram sect to invade Abuja. This report was not made available nor was there anyway the Court could determine the veracity or otherwise of a report not brought before it. As earlier noted, right to life as enshrined in human rights instruments is very fundamental because other rights necessarily depend on it. Secondly, there is substantive and procedural responsibility imposed on States by the International Human Rights Standard. Was there any thorough investigation of this incident by the Defendant? If not, this will also engage the responsibility of the Defendant. As the European Court of Human Rights held in the case of MAKARATZIS Vs. GREECE (2004) ECHR 5038/ 99 AT PARA 58, national law regulating Police operation must be put on ground a system of adequate and effective safeguards against arbitrariness and abuse of force even against avoidable accident. Indeed, the obligation to protect the right to life, if read together with the States general duty under Article 1 of the African Charter, requires, by implication, that there should be some form of effective official investigation when individuals have been killed as a result of force (see CAKICI VS. TURKEY) (1999) ECHR 23657/94 at para 88. The essential purpose of such investigation is to secure the effective implementation of the domestic laws safeguarding the right to life, and in those cases involving States’ agents or bodies to ensure their accountability for deaths occurring under their responsibility (SEE ANGUELORA VS. BULGARIA (2002) ECHR 38361197 at para 137. 44