Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook the Court also considered the fact that under Bulgarian law it was not possible for a complainant to initiate a criminal prosecution in respect of offences allegedly committed by agents of the State in the performance of their duties. The Court went on to state in paragraph 102 of its judgment: Where an individual raises an arguable claim that he has been seriously ill-treated by the police or other such agents of the State unlawfully and in breach of Article 3, that provision, read in conjunction with the State’s general duty under Article 1 of the Convention to secure to everyone within their jurisdiction the rights and freedoms defined in […] [the] Convention, requires by implication that there should be an effective official investigation. This investigation, as with that under Article 2, should be capable of leading to the identification and punishment of those responsible… If this were not the case, the general legal prohibition of torture and inhuman and degrading treatment and punishment, despite its fundamental importance, would be ineffective in practice and it would be possible in some cases for agents of the State to abuse the rights of those within their control with virtual impunity. It follows, therefore, that in the context of Article 3 complaints, a civil or an administrative action in respect of illegal acts attributable to a State or its agents may only be regarded as an effective remedy where that remedy is capable of establishing the circumstances of the ill-treatment and of leading to the identification and punishment of those responsible. Civil or administrative proceedings aimed solely at awarding damages rather than identifying and punishing those responsible will not in principle be regarded as effective remedies in the context of Article 3 complaints.450 However, recent jurisprudence has accepted that administrative court proceedings aimed at monetary compensation for inadequate conditions in detention were an effective remedy451 “as part of the range of possible remedies.”452 They could not, however, be “considered an effective mechanism in order to put an end to such treatment rapidly,”453 as required by the Convention. The Court has explained: In the context of complaints about inhuman or degrading conditions of detention, […] two types of relief are possible: an improvement in the material conditions of detention, and compensation for the damage or loss sustained on account of such conditions.[454] If an applicant has been held in conditions in breach of Article 3, 450 See Tepe v. Turkey (dec.), no. 31247/96, 22 January 2002; Yaşa v. Turkey, no. 22495/93, 2 September 1998, § 74. 451 See Timofejevi v. Latvia, no. 45393/04, 11 December 2012, § 69; Ignats v. Latvia (dec.), no. 38494/05, 24 September 2013, § 112; Norbert Sikorski v. Poland, no. 17599/05, 22 October 2009, § 116; Lienhardt v. France (dec.), no.12139/10, 13 September 2011, and Rhazali and Others v. France (dec.), no. 37568/09, 10 April 2012. 452 Aden Ahmed v. Malta, no. 55352/12, 23 July 2013, § 58, with reference to Z and Others v. the United Kingdom [GC], no. 29392/95, 10 May 2001, § 109; Keenan v. the United Kingdom, no. 27229/95, 3 April 2001, § 130, and Paul and Audrey Edwards v. the United Kingdom, no. 46477/99, 14 March 2002, §§ 97–98. 453 Aden Ahmed v. Malta, no. 55352, 23 July 2013, § 59. 454 See Roman Karasev v. Russia, no. 30251/03, 25 November 2010, § 79, and Benediktov v. Russia, no. 106/02, 10 May 2007, § 29. 128