Article 2 of the Convention relates not only to the direct actions of police officers or security forces, but also to the planning of operations or even the training of personnel of the relevant law enforcement agencies, if it can be proven that law enforcement officers have not undergone appropriate training or that their level of training is not commensurate with the complexity of the tasks assigned to them. One of the possible reasons for the killing of the applicants’ relative was the lack of adequate practical training for police officers.
- Celniku v. Greece
States must set high professional standards for their law enforcement systems and ensure that persons serving in such bodies meet the established requirements. In particular, when equipping police forces with firearms, care should be taken not only to provide appropriate special training for personnel, but also to carry out particularly thorough checks on employees before allowing them to carry such weapons.
- Saso Gorgiev v. the FYRM, Para 51;
- Abdullah Yilmaz v. Turkey, Paras 56-57;
- Enukidze and Girgvliani v. Georgia, Para 284