(2017) 1 African Human Rights Yearbook 3 Conceptually, extrajudicial killings of women are an extreme form of violence against women in general. Such killings result from a number of factors that predispose woman to that type of harm, a violation usually perpetrated by a family member or an intimate partner. The enabling factors of such killings include the culture of socalled ‘honour’ killings by male family or community members of women perceived to have brought ‘dishonour’ upon their natal family or their community.4 They also include the ingrained suspicion, in some rural communities, that elderly women are witches and so open to mob accusation and killing in the interest of the community. Another factor is the suspect patriarchal attitude in some settings that a woman is man’s ‘possession’ and may be killed when she ‘provokes’ him particularly by conduct that excites his sexual jealousy. In these cases, the factors that induce killing are female-specific, the killing is deliberate and takes place in an exclusive space. However, there is another category of extrajudicial killings of women in which death results from the perpetration of other forms of gender violence such as sexual or non-sexual assault in intimate partner relationships. Killing in those circumstances is not always understood as extrajudicial partly because in many instances it is difficult to divorce it from domestic violence. The proportion of the perpetration of each of these two categories of extrajudicial killings of women as against the other is difficult to ascertain because available homicide statistics make no such differentiation. 2 LEGAL ACCOUNTABILITY OF THE STATE IN THE CONTEXT OF EXTRAJUDICIAL KILLINGS In this section I consider in the broadest outline the standards, and the behavioural and substantive rules, which may be invoked to hold the state accountable in the context of extrajudicial killings. I also consider the circumstances of state accountability in international human rights law in the context of extrajudicial killings, a form of killing that is also a violation of the right to life guaranteed under human rights instruments. The discussion is framed around the conceptual distinction between two broad categories of perpetrators of extrajudicial killings, state and non-state actors. In the last part of this section I broach the matter of statistics on female victims of extrajudicial killings in Africa. 2.1 Standards and rules The object of every treaty, including human rights treaties, is to create and impose binding obligations on states that are party to it. Parties to 4 ‘Report of the Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions’, Doc A/71/372, 2 September 2016, para 99.

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