28 L.M. AND OTHERS v. RUSSIA JUDGMENT courts remained equally dismissive and focused on the nature of the offences committed rather than on an evaluation of the applicants’ claims made under Articles 2 and 3 (see paragraphs 14-17 above). 117. The Court has already found that the applicants attempted to lodge requests for asylum and refugee status, but were prevented from effectively participating in these proceedings (see paragraphs 101-05 above). 118. Having regard to the foregoing, the Court is not persuaded that the applicants’ allegations have been duly examined by the domestic authorities in any of the proceedings employed. It must, accordingly, assess whether there exists a real risk that the applicants would be subjected to treatment proscribed by Articles 2 and/or 3 if they were removed to Syria. (d) Existence of a real risk of ill-treatment or danger to life 119. The Court notes that a general situation of violence will not normally in itself entail a violation of Article 3 in the event of expulsion (see H.L.R. v. France, 29 April 1997, § 41, Reports of Judgments and Decisions 1997-III); however, it has never ruled out the possibility that the general situation of violence in a country of destination may be of a sufficient level of intensity as to entail that any removal to it would necessarily breach Article 3 of the Convention. Nevertheless, the Court would adopt such an approach only in the most extreme cases of general violence, where there is a real risk of ill-treatment simply by virtue of an individual being exposed to such violence on return (see N.A. v. the United Kingdom, no. 25904/07, § 115, 17 July 2008). 120. As a matter of comparison, when considering situations in different areas of Somalia, the Court concluded that the risks of generalised violence, dire humanitarian conditions and absence of the possibility of relocating internally without the danger of being exposed to a risk of ill-treatment could lead to a finding of breach of Article 3, unless it could be sufficiently demonstrated that special circumstances such as powerful clan or family connections could ensure the individual’s protection (see Sufi and Elmi v. the United Kingdom, nos. 8319/07 and 11449/07, §§ 293-96, 28 June 2011). 121. In assessing the intensity of the conflict in Mogadishu, the Court in Sufi and Elmi (cited above) applied the following criteria which had been identified by the United Kingdom Asylum and Immigration Tribunal in AM & AM ((armed conflict: risk categories) Somalia CG [2008] UKAIT 00091, § 241): “[F]irst, whether the parties to the conflict were either employing methods and tactics of warfare which increased the risk of civilian casualties or directly targeting civilians; secondly, whether the use of such methods and/or tactics was widespread among the parties to the conflict; thirdly, whether the fighting was localised or widespread; and finally, the number of civilians killed, injured and displaced as a result of the fighting.”