“Complaints must be investigated promptly and impartially by competent authorities so as to make the remedy effective.”86 228. The European Court has also expressed the importance of carrying out thorough investigations that are capable of leading to the identification and punishment of those responsible for any ill-treatment.87 Moreover, when examining whether an investigation is effective, the European Court AC HP R applied the following test in some of its cases: whether the authorities reacted effectively to the complaints at the relevant time;88 the length of time it takes for the investigation to commence;89 and whether there were delays in taking statements from the victims.90 229. In Assenov & Others v. Bulgaria, the European Court clearly addressed the notion of effective investigation that is not impartial and independent. In deciding on the alleged police misconduct against the Complainant, the Court noted that “It was necessary to take evidence from independent witnesses,” adding that …”the examination of two further witnesses, one of whom had only a vague recollection of the incidents in question, was not sufficient to rectify the deficiencies in the investigation up to that point.”91 The Court concluded that the lack of a thorough and effective 86 Human Rights Committee, General Comment 20, Article 7 (Forty-fourth session, 1992), Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.1 at 30 (1994). para 14. 87 See Ilhan v. Turkey (2000) ECHR. para 92 88 Labita v Italy (2000) ECHR. para. 131 89 Timurtas v. Turkey (2001) 33 E.H.R.R. 6 ECHR. para.89. 90 Assenov & Others v. Bulgaria (1998) ECHR. para 105 91 Ibid Para 105 67

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