determine what constitutes "reasonable given the circumstances". Additionally, case law in Canada has unambiguously held that the use of lethal force in defence of property alone is not reasonable. The changes made by the government were to clarify the laws involving self-defence and defence of property, and to help legal professionals to apply the law as believed to reflect the values Canadians hold to be acceptable. England and Wales In English common law a defendant may seek to avoid criminal or civil liability by claiming that he acted in self-defence. This requires the jury to determine whether the defendant believed that force was necessary to defend him or herself, their property, or to prevent a crime, and that the force used was reasonable. While there is no duty to retreat from an attacker and failure to do so is not conclusive evidence that a person did not act in self-defence, it may still be considered by the jury as a relevant factor when assessing the merits of a self-defence claim. The common law duty to retreat was repealed by the Criminal Law Act 1967. This duty never existed when a person is somewhere he has a lawful right to be, but due to the repeal, now extends to public places, etc. Germany German law allows self-defense against an unlawful attack, without any duty to retreat. Courts have interpreted this law as applicable to home invasion, including the use of lethal force against law enforcement in cases where the home owner was of the mistaken belief that the intrusion was an unlawful attack on his life. Ireland Under the terms of the Criminal Law (Defence and the Dwelling) Act 2011, property owners or residents are entitled to defend themselves with force, up to and including lethal force. Any individual who uses force against a trespasser is not guilty of an offense if he or she honestly believes that the intruder was there to commit a criminal act and posed a threat to life. However, there is a further provision which requires that the reaction to the intruder is such that another reasonable person in the same circumstances would likely employ. This provision acts as a safeguard against grossly disproportionate use of force, while still allowing a person to use force in nearly all circumstances. The law was introduced in response to DPP v. Pádraig Nally. The Act largely places previous Irish