In considering whether the United Kingdom's obligations under the European Convention on Human Rights1 apply extraterritorially the court must consider whether the Convention is capable of applying to the acts of a United Kingdom public authority outside the territory of the United Kingdom (ie the scope of the Human Rights Act 1998); and, if so, whether the acts complained of are acts to which the Act applies, in the sense that the victims were 'within the jurisdiction' of the United Kingdom
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