investigations6. Recently, the Court found that the State had a continuing obligation to investigate Article 3 complaints even following a decision striking out the complaint following a unilateral declaration 7. In the case of Strogan v Ukraine 8 , the Court reiterated that for the investigation to be regarded as “effective”, it should in principle be capable of leading to the establishment of the facts of the case and to the identification and punishment of those responsible: an obligation, not of result, but one of means. “Any deficiency in the investigation which undermines its ability to establish the cause of injuries or the identity of the persons responsible will risk falling foul of this standard, and a requirement of promptness and reasonable expedition is implicit in this context”. What constitutes effective investigations has been further defined, developed and refined by the Court. For example, for an investigation to be thorough, including where criminal culpability may be an issue, officers should be interviewed as suspects 9 . Additionally, failure to conduct a prompt and expeditious investigation may impact on its adequacy due to the increased risk of losing evidence because of delay5. During investigations the Court has found that there is an obligation to obtain full and accurate statements from officers2; and that there should be critical analysis of such testimonies 10 , avoiding the practice of accepting accounts provided to any investigation without question. Other refinements as to what actions may amount to effective investigations have been set out, for example, in the case of Alder v UK11. In this case, which was the first occasion that the UK government admitted to violating Articles 2 and 3, the UK government provided a unilateral declaration which affirmed that: “The Government accept that the lack of an effective and independent investigation in this case constitutes a violation of the procedural obligations in Articles 2 and 3 of the Convention. Further, the Government accept that the treatment that the Applicant’s brother received in police custody amounted to a substantive violation of Article 3 with 14 of the Convention. 6 Buldan v Turkey (28298/95) – judgement of 20 April 2004 Jeronovičs v. Latvia (44898/10) - judgment of 5 July 2016 Strogan v Ukraine (30198/11) – judgement of 6 October 2016 9 Ramsahai v The Netherlands (52391/99) – judgement of 15 May 2007 10 Kaya v Turkey (158/1996/777/978) – judgement of 19 February 1998 11 Alder v United Kingdom (42078/02) - judgement of 22 November 2011 7 8 6