Doubt in Favour of the Defendant, Guilty Beyond Reasonable Doubt allegations of torture and ill-treatment of political detainees under Article 3 of the ECHR. The applicants submitted evidence such as reports of different forms of torture and ill-treatment and a list of alleged victims.572 The respondent government (Greece) challenged the admissibility of this evidence, arguing that it was insufficient.573 Greece also introduced evidence contesting the allegations of torture and ill-treatment, such as Greek legislation, documentary evidence and statistics, and several International Committee of the Red Cross reports.574 The Commission declared the applicants’ allegations admissible, reasoning that although the applicants’ evidence was insufficient at this stage, considering the current situation in Greece,575 the remedies indicated by the Greek government were not sufficient or effective.576 The Commission stated that, before addressing the substance of the allegations, it was necessary “to take [a] position on certain issues which must determine [the Commission’s] examination of the evidence.”577 Thus, the question before the Commission was the “standard and means of proof to be applied” in evaluating the evidence submitted by the applicants.578 The Commission stated that the allegations “must be proved beyond reasonable doubt.”579 The Commission defined reasonable doubt as: A reasonable doubt means not a doubt based on a merely theoretical possibility or raised in order to avoid a disagreeable conclusion, but a doubt for which reasons can be given drawn from the facts presented.580 The Commission did not provide any authority to support its choice of the reasonable doubt standard, which was subsequently reaffirmed by the ECtHR and applied in several other cases. In Ireland581 case, one of the parties contested the applicability of the reasonable doubt standard in assessing evidence alleging a violation of Article 3 of the ECHR. Reaffirming that the reasonable doubt standard applied based on the Commission’s decision in the Greek case, the ECtHR further elaborated on the sufficiency of evidence required to meet this standard. It added that proof beyond reasonable doubt may follow from the coexistence of sufficiently strong, clear, and concordant inferences, or of similar unrebutted presumptions of fact. Greek, p. 187, paras. 6-7. Greek, p. 187, para. 4. 574 Greek, p. 188, para. 8. 575 The Commission specifically pointed to the dismissal of thirty judges and public prosecutors on 29 May 1968. See Greek, p. 187, para. 5. 576 Greek, p. 187, para. 5. 577 Greek, p. 194, para. 23. 578 Greek, p. 194, para. 23. 579 Greek, p. 196, para. 30. 580 Greek, p. 196, para. 30. 581 Ireland v. United Kingdom, 25 ECtHR, Ser. A, (1978), (hereinafter: Ireland). 572 573 124