Article 2 of the European Convention on Human Rights protects the right to life. The article contains a limited exception for the cases of lawful executions and sets out strictly controlled circumstances in which the deprivation of life may be justified. The exemption for the case of lawful executions has been subsequently further restricted by Protocols 6 (restriction of the death penalty to war time) and 13 (abolition of the death penalty), for those parties who are also parties to those protocols. The European Court of Human Rights has commented that "Article 2 ranks as one of the most fundamental provisions in the Convention". The obligations on a State under Article 2 consist of three principal aspects: the duty to refrain from unlawful deprivation of life; the duty to investigate suspicious deaths; and in certain circumstances, a positive obligation to take steps to prevent avoidable losses of life. Deprivation of life The first, and most obvious obligation under article 2 is for the state, through its agents, to refrain from itself causing the deprivation of life, that is to say that domestic law must regulate the permissible use of lethal force by agents of the state. The court first considered the obligations imposed by Article 2 in the case of McCann and Others v United Kingdom brought by the relatives of three individuals shot by members of the SAS in Gibraltar. This case imposes two obligations to the State: To conduct a full, open and transparent investigations into why the public bodies have taken a life. This should be public, independent and should involve members of the family of the victims (R (Amin) v S.O.S. Home Dept) A positive duty to refrain from unlawful killing, better expressed as the "Duty of command, control and training" i.e. to ensure those who take the life (such as police marksmen) are highly trained and overseen at all times. If the state has not followed these obligations then it will be found to be an unlawful killing. Further reading of cases on the matter include: Kelly and Others v UK; Osman v UK; McKerr v UK; Jordan v UK; Shanaghan v UK; and R(Amin) v SOS Home Dept itself. Positive duty to protect life in certain circumstances Article 2 has been interpreted to include the positive obligation of the state to ensure preventive measures are taken to protect citizens. The leading case on the