6 in line with the provisions of said treaties) are much more common in International Law – in this realm of protection – than they are in domestic law.13 18. State conduct needs to be oriented towards the result sought to be achieved through the application of the international laws on the protection of human rights. Some authors have identified an element that accounts for "some confusion" created by the incorporation of the distinction between obligations of conduct and obligations of result into R. Ago’s original draft (Articles 20 and 21), namely: a civil law (the law of obligations) distinction was transported into International Law,14 which distinction is neither clear nor of much significance at the international level.15 19. So much so that, for instance, Paul Reuter avoided reasoning in terms of such obligations, as the conditioning of the State’s conduct to reach the intended result is much more important than the distinction. Thus, following Jean Combacau’s perceptive observation, International Law still needs its very own theory of obligations – equipped with all relevant concepts -16, rather than one "imported" from other areas of the legal science. 20. As far as legal theory is concerned, the most enlightened international legal scholars have leaned towards obligations of result insofar as the protection of human rights is concerned. Ian Brownlie has perceptively warned against the questions and uncertainty that may flow from the alleged differentiation between obligations of conduct and obligations of result, and its ex post facto application in connection with treaties that were neither drafted nor signed with such distinction in mind.17 In turn, Pierre-Marie Dupuy criticized said distinction between obligations of conduct and obligations of result as "imprecise", "incomplète", "inexacte", in its pointless attempt, devoid of all practical effects, to address the coordination of the international and domestic legal systems.18 21. The fact that such distinction has had no real impact on international case law comes as no surprise. Thus, for instance, James Crawford, the last ILC rapporteur on the subject of State Responsibility, also a detractor of the distinction19 - which was left out of the final version of the Articles on State Responsibility approved by the ILC in 200120 - took note of the Judgment rendered by the European Court of Human Rights 13 . Cf. ibid., pp. 250-251, 255, 257-259, 262 and 269. 14 . I.e., a distinction related to the degree of freedom given to the obligor, to choose the means through which the obligation will be discharged and the result sought achieved. 15 . J. Combacau, "Obligations de résultat et obligations de comportement: quelques questions et pas de réponse", in Mélanges offerts à Paul Reuter - Le droit international: unité et diversité, Paris, Pédone, 1981, pp. 190, 198 and 200-202. 16 . Cf. ibid., pp. 203-204. 17 . I. Brownlie, State Responsibility - Part I, op. cit. supra n. (10), p. 241. 18 . P.-M. Dupuy, "Le fait générateur de la responsabilité internationale des États", 188 Recueil des Cours de l'Académie de Droit International de La Haye (1984) pp. 47-49; and cf. also P.-M. Dupuy, "Reviewing the Difficulties of Codification: On Ago's Classification of Obligations of Means and Obligations of Result in Relation to State Responsibility", 10 European Journal of International Law (1999) pp. 376-377. 19 . Cf. J. Crawford, The International Law Commission's Articles on State Responsibility, Cambridge, University Press, 2002, pp. 20-23. 20 . Cf. ibid., p. 344.