The right to peaceful assembly1 may engage the state's positive obligations to protect other people's rights: thus, for example, protests at risk of turning violent may engage the operational duty under Article 22, requiring the state to put in place sufficient measures to protect the lives of its citizens from the criminal acts of others3. When considering whether the authorities have complied with such positive obligations, the European Court of Human Rights has held that account must be taken of the difficulties involved in policing modern societies, the unpredictability of human conduct and the operational choices which must be
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