flict, and has noted the link between non-compliance with the international law rules prohibiting resort to armed force and the loss of innocent lives.243 Similarly, the European Court of Human Rights has applied the right to life to situations of armed conflict. These cases are explained below. The former UN Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions, Asma Jahangir, also addressed the issue of armed conflict in the counter-terrorism context. Specifically, she expressed concern about indiscriminate killing of civilians by security forces and about military forces being given the authority to shoot looters on sight. The Special Rapporteur reminded all parties to an armed conflict that they must respect the rights of the civilian population in accordance with international humanitarian and human rights law. She also emphasized that the right to life of civilians and persons hors de combat allows for no derogation, even in time of public emergency or in the context of a fight against terrorism.244 The use of the term “shoot to kill” in relation to counter-terrorism policies has also been criticized by the current UN Special Rapporteur, Philip Alston, who said that: The rhetoric of shoot-to-kill serves only to displace clear legal standards with a vaguely defined licence to kill, risking confusion among law enforcement officers, endangering innocent persons, and rationalizing mistakes, while avoiding the genuinely difficult challenges that are posed by the relevant threat.245 Positive obligations to safeguard life The Council of Europe Guidelines on Human Rights and the Fight against Terrorism provide that: States are under the obligation to take the measures needed to protect the fundamental rights of everyone within their jurisdiction against terrorist acts, especially the right to life. This positive obligation fully justifies States’ fight against terrorism in accordance with the present guidelines.246 Appropriate steps should be taken to safeguard the lives of those within the jurisdiction. This may involve the provision of information regarding a possible risk to life caused by actions of the state,247 and this obligation may extend to discouraging individuals from causing serious risks to their own health.248 States’ obligations to protect against the consequences of terrorism include: 243 Op. cit., note 237, HRC, General Comment No. 6, para. 2. 244 Report of the Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions, Asma Jahangir, doc. E/ CN.4/2004/7, 22 December 2003, paras. 27-29. 245 Report of the Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions, Philip Alston, doc. E/CN .4/2006/53, 8 March 2006, para 45. 246 Op. cit., note 11, CoE, Guidelines on Human Rights and the Fight against Terrorism, Guideline I (States’ obligation to protect everyone against terrorism). 247 “The Court considers that the first sentence of Article 2(1) enjoins the State not only to refrain from the intentional and unlawful taking of life, but also to take appropriate steps to safeguard the lives of those within its jurisdiction […] It has not been suggested that the respondent State intentionally sought to deprive the applicant of her life. The Court’s task is, therefore, to determine whether, given the circumstances of the case, the State did all that could have been required of it to prevent the applicant’s life from being avoidably put at risk”, ECtHR, L.C.B. v. UK, Case no. 14/1997/798/1001, 9 June 1998, para. 36. 248 In Barrett, the Commission found that the control and supervision of the supply and consumption of alcohol in a naval base and the care and attention the deceased received following his collapse were adequate to protect his right to life, ECommHR, Barrett v. UK, Application no. 30402/96, 9 April 1997. See also ECtHR, Öneryildiz v. Turkey, Application no. 48939/99, 30 November 2004, paras. 89-110. 100 Countering Terrorism, Protecting Human Rights