lethal force to the greatest extent possible. There could be situations where participants in the protest use violence, meaning they engage in the causing of injury, death or serious damage to property.91 Law enforcement officers have a primary duty to facilitate and protect the safety and rights of those participating in protests.92 Where law enforcement decides to intervene using force, any intervention must meet the principles of “legality, precaution, necessity, proportionality and accountability”.93 Use of force must only be used if other alternatives have been exhausted. Even where there is violence by some members of an assembly, the responsibility of authorities is to de-escalate the violent situation in order to allow peaceful protestors to continue with the exercise of their right to protest. Therefore, if the use of batons is unsuccessful to de-escalate violence during a protest, use of firearms as the next step would be unacceptable under international law since any use of force must be graduated.94 In Sri Lanka, SLCAT has observed that the Sri Lanka police has deployed excessive use of tear gas, batons, barriers welded with sharp spikes and then disguised with black tarp, use of both rubber bullets and live ammunition against peaceful protestors resulting in serious injurytoprotestors and even death in one instance. Children have also been impacted by the disproportionate use of tear gas and live ammunition, with one child in Rambukkana hospitalized with injuries due to use of force by police. Extra judicial executions are deliberate actions by state officials or agents of the state, who deliberate kill someone without previous judgment affording all legal guarantees of due process and fair trial. In this case, the killing of Chaminda Lakshan in Rambukkana, may amount to an extrajudicial killing by the police. General Comment No. 37 (2020) on Article 21 of the International Covenant on Civil and Political Rights in the Right to Peaceful Assembly (Article 21). https://documents-dds-ny.un.org/doc/UNDOC/GEN/G16/018/13/PDF/ G1601813.pdf?OpenElement 92 General Comment 37 (2020) 93 General Comment 37 (2020) at p.12 94 General Comment 37 (2020) at p.13 91 25