45 When ruling on a case involving the launch of tear gas grenades, the European Court of Human Rights stated that “firing a grenade by means of a launcher generates the risk of causing serious injury (…), or indeed of killing someone, if the grenade launcher is used improperly.”63 The Court has found that the inappropriate use of launchers to fire tear gas grenades directly at protesters on a flat trajectory violated Articles 2 and 3 of the European Convention on Human Rights – on the right to life and the prohibition of torture and other ill-treatment.64 Some launchers can be used to disseminate large amounts of chemical irritant over a wide area in a short space of time, indiscriminately affecting all those in the contaminated area. This can cause serious injury or death through asphyxiation, agent toxicity or kinetic impact of the projectile. The use of launchers could also lead to injuries resulting from panic and stampedes when used in larger enclosed areas or where there is only a limited possibility of exit. The UN Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions has expressed concern at the prospect of unmanned vehicles being used to police public gatherings: “Using unmanned systems to deliver force in the law enforcement context is also likely to be seen in many contexts as adding insult to injury, and an affront to human dignity. For example, using unmanned systems against striking mine workers, even if less lethal, could easily be viewed as less than human treatment.”65 Shotguns can be used to fire both lethal and less lethal rounds, creating the risk of unintentional use of lethal force. Though used less frequently to fire less lethal ammunition, the same applies to assault rifles and handguns. Shotguns and handguns are also inaccurate, with range and weather conditions having an additional effect. Multiple projectile rounds (e.g., rubber/plastic pellets) are inherently indiscriminate. These factors increase the risk of those other than the individuals targeted, including bystanders, being hit, particularly in the context of a public gathering. While all of the above-mentioned launchers and firearms can cause significant bodily harm, and sometimes death, firearms using conventional metal-jacketed ammunition are much more likely to have lethal effect. The UN Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions has stated that indiscriminate firing of such weapons into a crowd is always unlawful, even when some protesters 63 64 65 European Court of Human Rights, Abdullah Yaşa and Others v. Turkey, judgment of 16 July 2013, paragraph 42. European Court of Human Rights, Ataykaya v. Turkey, judgment of 22 July 2014, and Ibid. “Report of the Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions, Christof Heyns”, UN doc. A/69/265/, 6 August 2014, para. 85, <https://undocs.org/pdf?symbol=en/A/69/265>.