Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook exhaust these “futile”443 remedies, also noting the “absence of tangible progress in any of the criminal investigations over the years.”444 The Court has also dealt with applications introduced when criminal investigations continued for long periods of time without yielding any tangible results. In such cases, the respondent Government, who will in all likelihood object to the admissibility of the application on the basis of the applicant’s failure to await the conclusion of the proceedings, will be expected to prove that the proceedings in question are being conducted diligently and that they are capable of providing redress to the applicant. For example, in the case of Batı and Others v. Turkey, the applicants introduced their application with the Court while the criminal proceedings against the police officers suspected of having inflicted ill-treatment on them were still pending. Observing that the proceedings in question – a criminal trial – had continued for eight years during which time the judicial authorities had failed to take a number of important steps such as summoning and questioning the defendants directly and ensuring that the injuries of the applicants were medically examined, the Court held that the applicants had satisfied the obligation to exhaust the relevant remedies and were not required to await the conclusion of the criminal trial.445 According to the Court’s established case law, a mere doubt as to the prospect of success of a particular remedy is not sufficient to exempt an applicant from the requirement of exhausting that remedy.446 The Court’s decision on admissibility in Epözdemir v. Turkey447 provides a good example of this point. The Epözdemir case concerned the killing of the applicant’s husband by a group of four village guards. An autopsy was carried out and the body buried. The family of the deceased were not informed of the death of Mr. Epözdemir – despite the fact that the applicant had already informed the relevant prosecutor that her husband was missing – and no action was taken by the authorities to investigate the circumstances of the 443 444 445 446 447 126 especially those aimed at the identification and questioning of the military and security officers who could have witnessed or participated in the abduction; failure to involve the military prosecutors even where there was sufficient evidence of the servicemen’s involvement in the crimes; inability to trace the vehicles, their provenance and passage through military roadblocks; belated granting of victim status to the relatives; and failure to ensure public scrutiny by informing the next of kin of the important investigative steps and by granting them access to the results of the investigation.” Aslakhanova and Others v. Russia, nos. 2944/06, 8300/07, 50184/07, 332/08 and 42509/10, 18 December 2012, § 123. See Vakhayeva and Others v. Russia, no. 1758/04, 29 October 2009, § 157; Shokkarov and Others v. Russia, no. 41009/04, 3 May 2011, § 107, and Umarova and Others v. Russia, no. 25654/08, 31 July 2012, § 94. Yandiyev and Others v. Russia, nos. 34541/06, 43811/06 and 1578/07, 10 October 2013, § 109. Batı and Others v. Turkey, nos. 33097/96 and 57834/00, 3 June 2004, § 148. On the basis of those failures the Court also found a violation of Article 13 of the Convention. Whiteside v. the United Kingdom, no. 20357/92, Commission decision of 7 March 1994. See Epözdemir v. Turkey (dec.), no. 57039/00, 31 January 2002.