barriers, social stereotyping, cultural norms and lack of financial capacity. The justice chain- the series of steps that a woman has to take to access the formal justice system, often breaks down due to poverty, lack of legal awareness and discriminatory attitudes of service providers, including the police and judiciary. The ability of women to effectively utilize the legal and judicial procedure is circumscribed by a wide array of other factors also such as lower literacy, lack of family support and lack of access to information about legal services. Article 6 Right to life 17. The right to life is the most fundamental of all human rights, without which all other rights are meaningless. Pursuant to the ratification of the ICCPR, Bangladesh has undertaken an obligation to ensure the right to life of individuals. Article 31 and 32 of the Constitution guarantee the right to life and personal liberty. Thus, Bangladesh is obliged to take measures to ensure the right to life, liberty and security of life. In Bangladesh, the right to life is frequently violated through extra-judicial killings which are characterized as ‘cross fires’ or ‘armed encounters’ by law enforcing agencies, and enforced disappearances. Recently two foreigners and four bloggers had been allegedly killed by Islamic militants in Bangladesh, which sent shock wave across the country. In the Universal Periodic Review (UPR) in 2009 and 2013, Bangladesh reaffirmed its stand on ‘zero tolerance’ against human rights violations by law enforcement agencies and against their impunity.7 But despite a reported decline in numbers, extra-judicial killings have continued. Reports of disappearance have also been a major concern in recent years The NHRC has received complaints of torture, unlawful detention, domestic violence inaction by government officials and enforced disappearance. In most cases, these complaints were related to law enforcement agencies including the Rapid Action Battalion (RAB) and it has asked relevant government agencies to investigate such incidents. During 2014 NHRC, has received complaints on enforced disappearance 14, extra judicial killings 2, custodial torture 17, abduction 8. However, NHRC also notes with concern, the regularity of reports by the NGOs and media of killings and torture by the law enforcing agencies. According to Ain-O-Salish Kendra (ASK), from January to August 2015, 135 persons were allegedly killed by law enforcement agencies8, 34 persons died in jail custody from January to June 20159, and there were 43 cases of enforced disappearances allegedly by law enforcement agencies and reported by family members for the period from January to August 2015.10 The victims include politicians, businessmen, students, teachers, and leaders and activists of the ruling and opposition parties. Some are recovered as dead after they were abducted.11 In many cases, the families of the disappeared claim that law enforcement agencies picked up the victims. However, the law enforcement agencies deny any knowledge about the disappeared.12 7 http://daccess-dds-ny.un.org/doc/UNDOC/GEN/G13/155/20/PDF/G1315520.pdf?OpenElement (para 7, 63,64) http://www.askbd.org/ask/2015/09/07/death-law-enforcement-agencies-january-august-2015/ 9 http://www.askbd.org/ask/2015/07/09/deaths-jail-custody-january-june-2015/ 10 http://www.askbd.org/ask/2015/09/07/enforced-disappearance-january-august-2015/ 11 Enforced disappearance, http://odhikar.org/enforced-disappearances/#sthash.MbmO6UpM.dpuf 8 12 Ibid. 9