A/HRC/4/20 page 28 95 A particularly significant example is that the recognition that mandatory death sentences were per se violations of human rights law stemmed from a gradual understanding through the adjudication of concrete cases that the “most serious crimes” limitation did not fully capture the concept of the non-arbitrary imposition of capital punishment. 96 Arbitrary and Summary Executions, Note by the Secretary-General, E/AC.57/1984/16, paras. 40-43 (25 January 1984). 97 Safeguards, para. 1. 98 ECOSOC Res. 1984/50 (25 May 1984); GA Res. 39/118 (14 December 1984). 99 ECOSOC Res. 1990/51 (24 July 1990). 100 Capital punishment and implementation of the safeguards guaranteeing protection of the rights of those facing the death penalty, E/2000/3 (31 March 2000), para. 79. Additional insights are provided by the views of the European Union. After reviewing the resolutions of the GA and the provisions of the ICCPR and the Safeguards, in its Guidelines to EU Policy Towards Third Countries on the Death Penalty, the European Council determined that, among the minimum standards that should be met by all States maintaining the death penalty, is: Capital punishment may be imposed only for the most serious crimes, it being understood that their scope should not go beyond intentional crimes with lethal or other extremely grave consequences. The death penalty should not be imposed for non-violent financial crimes or for non-violent religious practice or expression of conscience. (Guidelines to EU Policy Towards Third Countries on the Death Penalty (3 June 1988), at http://www.eurunion.org/legislat/DeathPenalty/Guidelines.htm.) In keeping with the erga omnes character of the right to life, the EU has elected to make démarches to non-EU countries regarding practices deviating from this and other minimum standards. (See Roger Hood, The Death Penalty: A Worldwide Perspective (3rd ed. 2002), pp. 16-18.) 101 This kind of legal offence-specific legal analysis also takes place at the national level. For a number of papers working out the implications of the most serious crimes standard for particular offences, ranging from illegally raising capital to smuggling precious metals, within a single legal system see The Road to the Abolition of the Death Penalty in China: Regarding the Abolition of the Non-Violent Crime at the Present Stage (Press of Chinese People’s Public Security University of China, 2004). 102 CCPR/CO/72/GTM, para. 17 (2001) (Guatemala). 103 A/50/40, para. 35 (1995) (Sri Lanka). 104 CCPR/C/79/Add.25, para. 8 (1993) (Islamic Republic of Iran).