In 1996, the UN Economic and Social Council adopted resolution 1996/1529 Safeguards Guaranteeing Protection of the Rights of Those Facing the Death Penalty as follows: Calls upon Member States in which the death penalty has not been abolished to effectively apply the safeguards guaranteeing protection of the rights of those facing the death penalty, in which it is stated that capital punishment may be imposed only for the most serious crimes, it being understood that their scope should not go beyond intentional crimes 37 with lethal or other extremely grave consequences. Finally, in its draft General Comment No. 36, the HR elaborates on the meaning of the term "the most serious crimes" in Article 6(2) of the ICCPR. The Committee notes that the term must be “read restrictively and appertain to crimes of extreme gravity, such as... premeditated murder or genocidal killings.”38 The Committee further states that in the case of offenses not resulting directly or intentionally in death, such as in drug offenses, attempted murder, corruption, armed robbery, piracy, abduction, repeated evasion of compulsory military service, and sexual offenses, the death penalty should not be imposed. In the view of the Committee, such crimes, although serious in nature, “do not manifest the extraordinary high levels of violence, utter disregard for human life, blatant anti-social attitude and irreversible consequences that could conceivably justify the imposition of the death penalty as a form of legal retribution.”39 Numerous decisions of domestic Courts are consistent with the narrow construction of the term “most serious crimes,” and, equally, the breadth of the Article 6 guarantee of a right to life. For example, in South Africa, the imposition of the death penalty in any circumstances has been described as constituting inhuman and degrading treatment by the Constitutional Court in S v Makwanyane.40 More recently in 2011, the South Gauteng High Court in South Africa undertook a detailed consideration of the right to life in the context of an extradition request made by Botswana, a State which maintained the death penalty.41 The South Gauteng High Court described Botswana as “a pariah state not synchronized with the majority of African countries that have either abandoned or are refusing to implement the death 37 UN Economic and Social Council, Safeguards guaranteeing protection of the rights of those facing the death penalty Resolution 1996/15 (July 23, 1996), ¶ 2, available at http://www.un.org/documents/ecosoc/res/1996/eres1996-15.htm (last accessed Feb. 28, 2017). 38 UN Human Rights Committee, Draft General Comment no. 36: Article 6: Right to Life, U.N. Doc. CCPR/C/GC/R.36/Rev.2 (Sept. 02, 2015), ¶ 37. 39 Id. 40 S v. Makwanyane, Constitutional Court (South Africa), ZACC 3; 1995 (3) SA 391 (CC) (1995). 41 Tsebe and Another v Minister of Home Affairs and Others, Phale v Minister of Home Affairs and Others [2011] ZAGPJHC 115; 2012 (1) BCLR 77 (GSJ); [2012] 1 All SA 83 (GSJ); see also the decision of the Constitutional Court Minister of Home Affairs v Tsebe 2012 (5) SA 467). Page 13 of 23