For an investigation into alleged unlawful killing by state agents1 to be effective, it is necessary for the persons responsible for and carrying out the investigation to be independent from those implicated in the events, which entails not only a lack of hierarchical or institutional connection but also a practical independence2. There must also be a sufficient element of public scrutiny of the investigation or its results to secure accountability in practice as well as in theory: the degree of public scrutiny required may well vary from case to case, although in all cases the victim's next-of-kin must be
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