Zimbabwe Rule of Law Journal |137 that as it may, it is difficult to see how a court could use the doctrine of necessity to allow some sort of defence to the killing of a person as a last resort to defend property. Killing under Compulsion The problems with some of the other defences, such as compulsion, are even more acute. Under sections 243 and 244 of the Criminal Law Code where all the stringent requirements for the defence are satisfied, X has the defence of compulsion where he kills Z because Y has threatened to kill X unless he kills Z. Even though X was forced to kill the third person to save his own life, the fact remains that the person who dies is an innocent individual who has a constitutionally guaranteed right to life. Killing to Arrest The provision in section 42 of the Criminal Procedure and Evidence Act previously laid down that a person authorized to arrest a person may lawfully kill a person who is resisting arrest or is fleeing, provided that the person was being arrested on the ground that he was committing or had committed, or was suspected on reasonable grounds of committing or having committed a First Schedule offence. It was arguable that the use of lethal force to effect an arrest is not justifiable but even if lethal force is justifiable in extreme circumstances, that provision was surely too wide. A First Schedule offence is any offence in terms of any enactment in respect of which a punishment of a period of imprisonment exceeding six months is provided and may be imposed without the option of a fine. This would cover relatively trivial offences and killing to prevent escape is not justifiable for such offences. Secondly, it covered killing where there is only a reasonable suspicion that such an offence has been committed. If we are going to have an exception to the right to life on this ground the ambit of lawful killing must be drastically narrowed down. However, section 14 of Act 2 of 2016 has replaced this section with a new section 42 that substantially restricts the right to use lethal force to effect an arrest or prevent an escape. The force