an obligation to establish a framework of laws precautions, procedures and means of enforcement which will, to the greatest extent reasonably practicable, protect life. In the case of Osman [1] it was stated that this obligation amounted to:

"putting in place effective criminal law provisions to deter the commission of offences against the person backed up by law-enforcement machinery for the prevention, supression and sanctioning of breaches of such provisions"

a procedural obligation which includes the "minimum requirement of a mechanism" so that the circumstances of certain kinds of deaths will be subject to "public and independent scrutiny". In Osman the court said:

" The nature and degree of scrutiny which satisfies this minimum threshold must, in the Commission's view, depend on the circumstances of the particular case. There may be cases where the facts surrounding a deprivation of life are clear and undisputed and the subsequent inquisitorial examination may legitimately be reduced to a minimum formality. But equally, there may be other cases, where a victim dies in circumstances which are unclear, in which event the lack of any effective procedure to investigate the cause of the deprivation of life could by itself raise an issue under article 2 of the Convention."to undertake an investigation into certain kinds of deaths."

The case of Amin, makes clear, however that, "The state's duty to investigate is secondary to the duties not to take life unlawfully and to protect life in the sense that it only arises where a death has occurred or life=threatending injuries have occurred" (para 31)