Frances McClenaghan and Deborah Britstone discuss the Supreme Court decision in Northern Ireland No 1,2 and 3 and the Human Rights Act 1998. The Supreme Court provided guidance on three key matters: the extent to which the investigative duty under Article 2/3 of the ECHR is engaged in pre-commencement deaths, when new evidence revives the investigative obligation and how the court assesses the independence of investigations.