For transitive clauses, " instrument is the case of the object accessory or tool involved in performing the action of the verb." They are always inanimate. With an actor, it appears as the last noun phrase in the clause, marked with post-verbal ablative particle "le". Without an actor, it may appear as the clause topic. "it is not a plausible analysis to regard "le" marking Instrument-NP as signalling Instrument outranked by another role (Patient), like English with, since this alternative does not explain the invariant ordering of the instrumental clause."