may be sufficient. McCann v UK inquest held also satisfied the investigation requirement provided it is fair and impartial. Nachova v Bulgaria shows that the state has a positive obligation to investigate death upon becoming aware of it, as opposed to receiving a complaint by family members. Yasa v Turkey shows that a State of emergency DOES NOT excuse the obligation to investigate deaths. Hugh Jordan v UK - The investigation can vary so long as it meets the strict requirements of effectiveness. Effectiveness thus creates certain criteria to be followed: Investigators must be 'independent and impartial both at law and in practice'. Nachova v Bulgaria also requires good impartial conclusion based on evidence. Ergi v Turkey - There was a breach because the investigators relied solely on evidence provided by the police who were being investigated. Ramsahai v Netherlands - Evidence provided by the colleagues of those being investigated does not satisfy the requirements for impartial investigations even as in the case of Jordan v UK, the colleagues where supervised by independent body. Jordan v UK - investigation must be adequate, adequacy requires the investigation to show the cause of death and find those responsible for it. Jordan v UK - investigation must be fast and reasonably expedient. McKerr v UK - must allow for public scrutiny and provide punishments that would deter others, Oneryildiz v Turkey - Methane explosion in refuse tip caused a landslide which killed dozens of people living in a slum. The investigation found only 2 mayors to bear any responsibility who were given suspended sentences and the minimum statutory fine just under 10 euros. this was held by the court to fail in its requirement to allow public scrutiny and deter others. as in Jordan, Legal Aid may also need to be provided. Abortion cases Article 3 does not recognize an absolute right to life, in abortion cases there is a wide margin of appreciation because of the lack of consensus in Europe. X v UK - abortion of 10-week-old fetus to protect physical and mental health of women was not a breach. H v Norway - abortion of 12-week-old fetus for social reasons, to prevent putting the women in a 'difficult situation in life (literal interpretation of Norwegian statute)' was NOT A BREACH, again due to lack of consensus in Europe on the issue of abortion. The case was brought by the expectant