This chapter demonstrates the use of a restrictive 'state centred' accountability theory as the basis of protection under the Refugees Convention. The external or diplomatic protection view raises the issue of the relevance of internal protection of the refugee definition. The chapter summarizes some approaches which have developed in the context of persecution by non-state agents, which can be associated with an accountability approach. The public-private distinction is implicit in the motivation cases where the technique is to ask whether the applicant has been persecuted, in the sense of being discriminated against, for motives linked to Convention reasons. In the context of civil war and internal conflict, a distinction has been made between laws or acts which apply to the general populace and those which single out an individual or group of individuals. The Minister for Immigration argued that persecution and protection are distinct concepts, and that the absence of state protection did not convert private harm to persecution.