A/HRC/41/CRP.1 documented, including against activists living abroad. This is deeply regrettable. Saudi Arabia should instead not only be prepared to account for the execution of Mr. Khashoggi but also take active steps to demonstrate non-repetition. 424. The Special Rapporteur identifies below a range of options by which legal accountability for the execution of Mr. Khashoggi could be delivered. However, she warns that the search for accountability cannot privilege justiciability over all other means. His execution should result in all those responsible being held to account before a court of law and in provision by the State of remedies and reparations. But the search for, and narrative about, justice for Mr. Khashoggi cannot be left hanging on complex questions of jurisdiction and State claims to immunity and on the whims of the Saudi legal system. The onus is on the international community (States, civil society, corporate actors, United Nations) to search for, identify and implement other tools of accountability, including political, diplomatic, economic and symbolic. 425. Finally, the Special Rapporteur believes that search for accountability for the execution of Mr. Khashoggi should be commensurate with Mr. Khashoggi’s courageous stands for democracy, transparency and press freedom, including in Saudi Arabia and for the Middle East more generally. Steps should be taken to lift the cloud of secrecy so that the State and the individuals responsible for his killing cannot hide behind their power and influence under a pretense of accountability which too many it seems are prepared to accept. I. A follow-up criminal investigation for the execution of Mr. Khashoggi 426. The UN Human Rights Council (“UNHRC”), the Security Council 346 or the UN Secretary General should demand a follow-up criminal investigation into Mr. Khashoggi’s killing. The UN largely devotes its investigative powers to human rights and cases of international conflict.347 The execution of Mr. Khashoggi raises an egregious underlying set of facts, as well as violations of fundamental human rights as well as of international law. The steps taken by Saudi Arabia, in response to the execution, are not only insufficient. Their responses have themselves violated international human rights standards, both substantively and procedurally and failed to address the violations of international law. The Human Rights Council, the Security Council or the UNSG should recognize this for the exceptional case that it is and proceed with an international follow-up criminal investigation. 427. It has been argued that for the UNSG to initiate an international criminal investigation into the killing of Mr. Khashoggi, Turkey must formally request such an investigation. While the Special Rapporteur encourages Turkey or indeed Saudi Arabia to officially demand such a follow up criminal investigation, she disagrees with the narrow understanding according to which Turkey should trigger such an investigation. The interest and rights of Mr. Khashoggi should not be linked to or dependent upon his presence on the territory of Turkey at the time of his execution, no more than they should they be linked to or dependent upon his country of citizenship, responsible for his killing. It would be absurd to limit the intervention of the UNSG to such scenarios, although, practically and politically, the cooperation of the States concerned is an important step towards the delivery of accountability. Nevertheless, any state should be able to make claims on behalf of Mr. Khashoggi and the violation of his right to life, to the UN Secretary General (and any other UN bodies). Most importantly, the Secretary 346 347 Article 34 of the U.N. Charter grants the Security Council investigatory power deriving from its mandate to ensure “the maintenance of international peace and security.” See, e.g., United Nations, “International Commissions of Inquiry, Fact-finding Missions: Home,” available at http://libraryresources.unog.ch/factfinding (listing U.N. investigations from 1963 to the present, including missions in, e.g., Timor-Leste, Lebanon, and Afghanistan); see also United Nations Security Council, “Commissions & Investigative Bodies,” available at https://www.un.org/securitycouncil/content/repertoire/ commissions-and-investigative-bodies (listing U.N. commissions and investigative bodies from 1946 to the present, including those dedicated to, e.g., Rwandan genocide and demobilization of armed resistance in Nicaragua). 85