‘The right to life’ is the most fundamental of human rights. It is the first specific right to be mentioned in the UN’s Universal Declaration of Human Rights (Article 3): Everyone has the right to life, liberty and security of person. It is the first of the ‘rights and freedoms’ in the European Convention on Human Rights (Article 2): Everyone’s right to life shall be protected by law. It is also the first right in The Philippines Bill of Rights (as set out in Article 3, Section 1 of the Constitution): No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws. In the words of Thomas Jefferson: The first duty of government is the protection of life, not its destruction. Abandon that, and you have abandoned all. Although the Petition refers to a range of different human rights that: a) have been violated and; and b) are at increasing risk of future violation, for the purposes of simplicity this amicus brief will focus attention on the right to life. It is difficult to envision circumstances in which the Honourable Commission would conclude there had been a breach of the ‘right to adequate housing’, for example, but not of ‘the right to life’. On the other hand, if the Honourable Commission finds a breach of the right to life, interferences with other rights may readily be inferred. 4.1 When is the right to life engaged? Generally speaking there are three aspects to the right to life: (i) (ii) (iii) a negative obligation to avoid action which deprives a person of their life; a positive duty to take reasonable steps to preserve life; and a procedural duty on States to conduct a proper investigation into alleged violations of the right to life. All three aspects are relevant to this Petition, which alleges that: 9