3. Analysis and recommendations For a police oversight system to be effective there should be at least six interdependent pillars of oversight and control: 1. internal oversight; 2. executive control (policy control, financial control and horizontal oversight by government agencies); 3. parliamentary oversight (members of parliament, parliamentary commissions of enquiry); 4. judicial review; 5. independent bodies such as national human rights institutions; and, 6. civil society oversight20. Within the context of this revised assessment of police oversight an exhaustive review of the literature tells us that democracies deal with complaints against the police in many different ways, which often reflects the contexts of each jurisdiction. It is evident, that across several states, challenging a culture of police impropriety and developing legitimate oversight mechanisms are both closely aligned and clear policy objectives. The review suggests that a set of basic principles are clearly necessary when designing a system which provides assurance to citizens that police oversight mechanisms are sound and their complaints are handled appropriately and effectively. These basic principles of effective police complaints investigations have been developed in the jurisprudence of the European Court of Human Rights on Articles 2 and 3 of the European Convention on Human Rights as: Independence; Adequacy; Promptness; Public scrutiny; and Victim involvement21. Within the context of the basic principles, the systems, which provide the highest degree of assurance in terms of fairness and effectiveness, are those that demonstrate the most independence from the police along with high levels of public scrutiny and victim involvement. The key to restoring or enhancing public confidence in the police is openness to external review and oversight. The practical outworkings of such independence is that investigations can legitimately encompass those which engage Articles 2 and 3 of the ECHR or other serious human rights violations which demand a high level of independence from existing police and governmental structures22. 20 OSCE TNTD/SPMU Publication on “Police Reform within the Framework of Criminal Justice System Reform”, July 2013 (hereinafter “2013 OSCE Publication on Police Reform”), available at http://www.osce.org/secretariat/109917?download=true 21 Erik Svanidze (2014) Effective Investigation of Ill-Treatment; Guidelines on European Standards Second Edition. Council of Europe, Strasbourg. 22 The ECtHR has developed specific requirements as to the role of the prosecuting authorities. Thus, in its judgment in the case of Najafli v. Azerbaijan, 3 October 2012, the ECtHR suggested: ‘The Court has repeatedly stressed that the procedural obligation under Articles 2 and 3 requires an investigation to be independent and impartial, both in law and in practice. The Court notes that the Sabail District Prosecutor’s Office, which was formally an independent 67