PART 2: How to Bring a Case to the Court conducted out of a hearing and possibly out of the sight of police officers. In addition, results of examinations as well as statements by the detainee and doctors should be formally recorded and made available to the detainee and his or her lawyer.153 When examining allegations of ill-treatment, the Court takes these standards into account. For example, in the case of Akkoç v. Turkey,154 the applicant alleged that she had been subjected to ill-treatment in police custody which included being doused with hot and cold water and subjected to electric shocks and blows to the face. Upon release she was brought together with sixteen other detainees before a doctor who stated in a “medical report” that they had not suffered any physical blows. A few days after her release, she was medically examined at a university hospital where x-rays of her head were taken showing that her chin had been broken. The Commission, after holding a fact-finding hearing in Turkey and hearing a number of persons who had witnessed the applicant’s state of health following her release from police custody, concluded that she had indeed been subjected to the treatment described in her application form. This conclusion was subsequently upheld by the Court, which found a violation of Article 3 of the Convention. In its judgment the Court stated the following: The Court further endorses the comments expressed by the Commission concerning the importance of independent and thorough examinations of persons on release from detention. The European Committee for the Prevention of Torture (CPT) has also emphasised that proper medical examinations are an essential safeguard against ill-treatment of persons in custody. Such examinations must be carried out by a properly qualified doctor, without any police officer being present and the report of the examination must include not only the detail of any injuries found, but the explanations given by the patient as to how they occurred and the opinion of the doctor as to whether the injuries are consistent with those explanations. The practices of cursory and collective examinations illustrated by the present case undermines [sic] the effectiveness and reliability of this safeguard.155 The lack of medical evidence in an ill-treatment case will not necessarily mean that the applicant will be unable to prove his or her allegations of ill-treatment. In the case of Tekin v. Turkey the Court observed that [i]t is true that, as the Government have pointed out, the applicant was unable to provide any independent evidence, for example medical reports, to substantiate his allegations of ill-treatment. However, in this respect the Court notes that the State authorities took no steps to ensure that Mr Tekin was seen by a doctor during his time in detention or upon his release, despite the fact that he had complained of ill-treatment to the public prosecutor […] who was under a duty under Turkish law to investigate this complaint.156 154 Akkoç v. Turkey, nos. 22947/93 and 22948/93, 10 October 2000. 155 Ibid., § 118. 156 Tekin v. Turkey, no. 22496/93, 9 June 1998, § 41. 69