Report of the Polish Commissioner for Human Rights on the Activities of the National Mechanism for the Prevention ... cluding, inter alia, eyewitness testimony and forensic evidence. In this context, immediate and prompt action is required. 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. In all those cases and, e.g., in the cases Pieniak v. Poland148, Mrozowski v. Poland149 and Polanowski v. Poland150 the ECHR considered that the state has failed to provide a plausible explanation of the allegations of inhumane treatment by state service officers. Despite the fact that in its Resolution no. CM/ResDH (2016)148 of 8 June 2016 the Committee of Ministers of the Council of Europe admitted that Poland implemented the aforementioned judgments, there is no doubt the Polish State institutions should continue their efforts to increase protection against torture and ill-treatment. Article 2(1) of the Convention provides that a State Party should take effective legislative, administrative, judicial or other measures to prevent acts of torture in any territory under its jurisdiction. According to the doctrine, the regulation should be interpreted as covering the states’ obligation to respect human rights and not to use torture. However, the main emphasis is placed on the positive obligation to take effective measures151. In view of the above, on 30 June 2016 the Commissioner for Human Rights appealed to the Minister of the Interior and Administration to develop, based on the Istanbul Protocol materials, a single procedure applicable to all uniformed services152. The procedure should be mandatory in the case of any contact with a person in relation to whom the use of inhuman treatment or torture is suspected. The procedure, for example issued in the form of a manual, should explain, step-by-step, the measures to be taken in order to identify the victim and secure the evidence. The Commissioner also suggested to carry out a series of training sessions for uniformed services to address the subject of torture and other inhuman or degrading treatment or punishment, and methods of investigating and documenting such cases153. Application no. 19616/04, judgment of 24February 2009. Application no. 9258/04, judgment of 12 May 2009. 150 Application no. 16381/05, judgment of 27 July 2010. 151 William A. Schabas, The European Convention on Human Rights, a Commentary, Oxford, 2015, p. 133. 152 CHR’s general intervention of 30.06.2016 to the MIA regarding the development of medical procedures applicable to detainees, ref. no. KMP.400.9.2015.WS2. 153 CHR’s general intervention of 30.06.2016 to the MIA on the organization of training for uniformed services, ref. no. KMP.400.9.2015.WS1. 148 149 54