One of the obligations that the State must inescapably undertake as guarantor, to protect and ensure the right to life, is that of generating minimum living conditions that are compatible with the dignity of the human person and of not creating conditions that hinder or impede it. In this regard, the State has the duty to take positive, concrete measures geared toward fulfillment of the right to a decent life, especially in the case of persons who are vulnerable and at risk, whose care becomes a high priority. 220 Like the other regional bodies, the European Court of Human Rights (ECtHR) recognizes that States, under article 2.1 of the European Convention on Human Rights (ECHR), have a positive obligation “not only to refrain from the intentional and unlawful taking of life, but also to take appropriate steps to safeguard the lives of those within its jurisdiction.” 221 In Öneryildiz v. Turkey, the ECtHR stressed that this obligation “entails above all a primary duty on the State to put in place a legislative and administrative framework designed to provide effective deterrence against threats to the right to life.”222 It further clarified that this duty included an obligation for the State to “govern the licensing, setting up, operation, security and supervision” of the dangerous and hazardous activities and to adopt or establish procedures to guarantee this regulation is effective.223 Domestic courts’ decisions also imply that States have an affirmative responsibility to protect citizens. For example, in T. Damodhar Rao v. Municipal Corp. of Hyderabad, the High Court of Andhra Pradesh held that constructing houses in a designated recreational area was contrary to the right to life protected under Article 21 of India's Constitution: There can be no reason why practice of violent extinguishment of life alone should be regarded as violative of Art. 21 of the Constitution. The slow poisoning by the polluted atmosphere caused by environmental pollution and spoilation should also be regarded as amounting to violation of Art. 21 . . .224 “[I]t is clear that protection of the environment is not only the duty of the citizen but it is also the obligation of the State and all other State organs including Courts…. It, therefore, becomes the legitimate duty of the Courts as the enforcing organs of Constitutional objectives to forbid all action of the State and the citizen from upsetting the environmental balance.” 225 C. International law requires states to protect human rights from abuse by private actors and to exercise jurisdiction over the conduct of businesses that constitutes human rights abuse226 Human rights law imposes upon States wide-ranging obligations to protect the human rights of individuals from infringements by third parties, including corporations. As a 220 Id. at ¶ 162 (internal footnote omitted). L.C.B. v. the United Kingdom, App. No. 23413/94, Eur. Ct. H. R., at §36 (1998). 222 Öneryildiz v. Turkey [GC], App. No. 48939/99, Eur. Ct. H. R., at §89 (2004). 223 Id. at § 90. 224 T. Damodhar Rao v. Municipal Corp. of Hyderabad, 1987 A.I.R (AP) 171, ¶ 24. 225 Id. at ¶¶ 24-25. 226 This matter is also addressed early in this joint summary amicus brief in Section I on Jurisdiction, supra, as it is relevant to the Commission’s jurisdiction to conduct an inquiry. 221 47