Observations for Sri Lanka, the HRC stated that “drug-related offences” were not “serious crimes” within the meaning of Article 6.31 Further, in Luboto v. Zambia, the HRC concluded that there had been a violation of Article 6(2) because the petitioner had been sentenced to death under a law imposing a mandatory sentence of death for aggravated robbery in which firearms were used. The Committee observed that “use of firearms did not produce the death or wounding of any person and that the court could not under the law take these elements into account in imposing sentence.” 32 The position of the HRC is consistent with that taken by other United Nations bodies. The fundamental obligation to limit the death penalty to the most serious crimes was emphasised by the UN Economic & Social Council in 1984 when it adopted the “Safeguards Guaranteeing Protection of the Rights of Those Facing the Death Penalty.”33 The Safeguards were endorsed by the UN General Assembly in resolution 39/118.34 The Safeguards Guarantee stated that: In countries which have not abolished the death penalty, capital punishment may be imposed only for the most serious crimes, it being understood that their scope should not go beyond intentional crimes with 35 lethal or other extremely grave consequences. Similarly, Resolution 2005/59 of the former United Nations Commission on Human Rights provided that States which retained the death penalty were obliged: Not to impose the death penalty for any but the most serious crimes [and] to ensure also that the notion of “most serious crimes” does not go beyond intentional crimes with lethal or extremely grave consequences and that the death penalty is not imposed for non-violent acts such as financial crimes, religious practice or expression of conscience and sexual 36 relations between consenting adults nor as a mandatory sentence. 31 UN General Assembly, Report of the Human Rights Committee, U.N. Doc. A/50/40 (Oct. 03, 1995), ¶ 449. UN Human Rights Committee, Luboto v. Zambia, Communication No. 390/1990, U.N. Doc. CCPR/C/55/D/390/1990/Rev.1 (1995) (June 30, 1994). 33 UN Economic and Social Council, Safeguards guaranteeing protection of the rights of those facing the death penalty, resolution 1984/50 (25 May 1984), available at http://www.ohchr.org/Documents/ProfessionalInterest/protection.pdf (laast accessed Mar. 03, 2017). 34 UN General Assembly, Human rights in the administration of justice, (14 December 1984), available at http://www.un.org/en/ga/search/view_doc.asp?symbol=A/RES/39/118 (last accessedFeb. 28, 2017). 35 UN Economic and Social Council, supra note 33 at ¶ 1. 36 UN Commission on Human Rights, Human Rights Resolution 2005/59: The Question of the Death Penalty, E/CN.4/RES/2005/59 (Apr. 20, 2005), available at http://www.refworld.org/docid/45377c730.html (last accessed Feb.27, 2017). 32 Page 12 of 23