lethal force, by States or their agents acting under color of law, or by an organized armed group in armed conflict, against a specific individual who is not in the physical custody of the perpetrator.”33 While targeted killings can be permitted in certain circumstances under the paradigm of hostilities during armed conflict, under the law enforcement paradigm a targeted killing as defined above can never be lawful, as killing someone cannot be the objective of a law enforcement operation.34 This prohibition stems from the non-derogable35 nature of the ‘right to life’ as recognized by Article 3 of the UDHR and Article 6 of the ICCPR, which recognizes that “Every human being has the inherent right to life”, adding that this right "shall be protected by law."36 These provisions make it the duty of states to protect and ensure the right to life37, and therefore, the use of lethal force is only allowed if it is absolutely necessary to save life.38 On top of the aforementioned human rights treaties, law enforcement activities are also governed by the United Nations Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (Basic Principles) and the Code of Conduct for Law Enforcement Officials. These are known as ‘soft law’ instruments,39 but their provisions have been incorporated to the customary international law, which is binding.40 The Basic Principles establish that “Law enforcement officials shall not use firearms against persons except in self-defense or defense of others against the imminent threat of death or serious injury,” “only when less extreme means are insufficient to achieve these objectives” and only “when strictly unavoidable in order to protect life.”41 The Code of Conduct of Law Enforcement Officials adopted by the UNGA adds that “Law enforcement officials may use force only when strictly necessary and to the extent required 33 UN Special Rapporteur Philip Alston, Report of the Special Rapporteur on extrajudicial, summary or arbitrary executions (A/HRC/10/24/Add.6), UN Human Rights Council, 28 May 2010, page 3. Available at: http://www2.ohchr.org/english/bodies/hrcouncil/docs/14session/A.HRC.14.24.Add6.pdf 34 Ibid., page 11 35 Non-derogable rights are those that can never be limited by states, even in times of public emergency that threatens the life of the nation 36 ICCPR, Article 6 37 Ibid., Article (2)(1) 38 UN Special Rapporteur Philip Alston, op.cit. (A/HRC/10/24/Add.6), page 11 39 The term "soft law" refers to quasi-legal instruments which do not have any legally binding force, or whose binding force is somewhat "weaker" than the binding force of traditional law, which is often contrasted with soft law by being referred to as "hard law." 40 Al-Haq, Unlawful Killing of Palestinians by Israeli Occupying Forces, 31 October 2015. Available at: http://www.alhaq.org/advocacy/topics/right-to-life-and-body-integrity/982-unlawful-killing-ofpalestinians-by-israeli-occupying-forces?format=pdf 41 Basic Principles, op. cit., General Provision No 9 18