Bulgaria- it is grossly disproportionate to use lethal force to effect an arrest, as the force cannot be considered absolutely necessary, especially when the person was not posing any threat, simply running away from Military Police who wanted to arrest him for dereliction of duty. Further, the court ruled in Kelly v UK that to shoot a person when seeking to arrest them defeats the purpose of the mission, which is to bring them before a court. It also rules out any future arrest and the fact that the victim will not get a chance to defend himself in law. Riots and insurrections Stewart v UK - 150 people throwing missiles at a patrol of soldiers amounted to a riot. Although the court has not laid down clear criteria as to what constitutes a riot. thus the force used firing plastic bullets killing a 13-year-old boy was proportionate. Gulec v Turkey - a crowd of several thousand throwing missiles at security forces and damaging property was also deemed to be a riot. There was however a breach here as the McCann obligations still apply regarding proportionality. So the security forces had fired shots at the ground near the rioters to scare them off. Ricochet bullets had thus killed applicants son. The Breach was found in that the authorities had no provided any riot equipment to the security forces even though a state of emergency was declared thus it was expectant that violence would occur. The operation had not been planned so as to minimize risk to the civilians. X v Belgium - Police officer shot an innocent bystander in the course of a riot. He had no authorisation to use the weapon thus his actions were not lawful, therefore clear breach. See also European Convention on Human Rights European Court of Human Rights References External links D. Korff The right to life. A guide to the implementation of Article 2 of the European Convention on Human Rights Strasbourg, Council of Europe, 2006 ECtHR factsheet on the abolition of death penalty 2