On March 29, 2015, the England and Wales High Court ruled [3] in Al-Saadoon v. Secretary of State for Defence that the European Convention on Human Rights (ECHR) applies to cases where Iraqi soldiers were shot by British forces during security operations. The main proceedings brought by Al-Saadoon and others represent at least 1,000 cases alleging “ill-treatment, unlawful detention and, in some cases, unlawful killing of Iraqi civilians by British soldiers” during the British military involvement in Iraq between 2003 and 2009. The claimants sought “orders from the court to require the Secretary of State for Defence to investigate alleged human rights violations.”  The Court considered whether the duty to investigate “applied to the use of force against Iraqi civilians who were not in the custody of British forces” and “the extent to which, where individuals were within the jurisdiction of the UK, there is a duty to investigate alleged violations of their rights.” The Court ruled that the duty to investigate may arise in some circumstances during handover (Article 2), detention (Article 5), and in cases where an individual is shot by a British soldier.