father who did not want the abortion carried out. Vo v France - abortion done as a result of mistaken name and thus medical negligence. The Court did not consider the right to life issue, rather stating that civil remedies where available and thus that satisfied the requirement for legal and administrative framework as set out in LBC. Evans v UK - same margin of appreciation doctrine as in VO, with specific reference to lack of European consensus thus necessitating a wide margin or appreciation. the ECHR cannot impose requirements, rather it protects minimum rights common to all the signatory states. Taking life by force of arms The taking of life by state agents is strictly prohibited except for exceptional circumstances, whilst private killings require investigation and legal and administrative protection. Makaratzis v Greece - Car chase by police, lead to them shooting wildly at the car. No death resulted but there was found to be liability as the nature of the incident could have been lethal, thus the inadequacy of planning and conduct of the officers constituted a breach. Killings by state agents are notoriously difficult to prove in many situations. In cases where a person is taken into custody, and dies, it is for the state to show how he died as was the case in Salman v Turkey. Demiray v Turkey - The explanation must be satisfactory. Akkoc v Turkey - Killing by suspected state agent. State refused to support investigation and provide evidence, thus the court turned the burden of proof on the state to justify with holding information. Estimarov v Russia - Reasons must be provided for the killing of the suspect. The Burden of Proof issue is a difficult one which is somewhat mitigated by the fact that the court finds breaches in failures to investigate. Thus is a death occurs the state is obligated to investigate it which it is unlikely to do where one of its agents is responsible, thus there is a breach. The investigation must also be effective as in Jordan v UK. In other words, the state is caught between a rock and hard place. In cases where persons have been detained by security forces and have subsequently disappeared the court has stated that two criteria must be satisfied: it must be shown beyond reasonable doubt that the missing person was detained by security forces or state agents. there