Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook Where possible, medical evidence obtained from institutions specialising in identifying and treating ill-treatment should also be submitted to the Court in support of allegations of ill-treatment.166 It is important to note that the Court requires applicants to bring medical evidence first to the attention of the national authorities to give them the opportunity to investigate allegations of ill-treatment. Failure to do so may result in the complaint being declared inadmissible for non-exhaustion of domestic remedies. This is illustrated in the case of Saraç v. Turkey167 in which the applicant argued that she had been taken into police custody where she was hung from her arms and hit repeatedly on the head with truncheons until she lost consciousness. While unconscious, her feet were burnt by cigarettes. Following this, she was raped with a truncheon on two occasions. She was then taken by car to an isolated place and abandoned. Thirteen days after the event in question the applicant went to the Human Rights Foundation of Turkey and sought medical assistance. Following medical examinations carried out over a period of three days in two different hospitals and the Nuclear Medical Centre in Istanbul, including gynaecological and neurological tests, x-rays, thorax graphics, scintigraphic imaging, and examinations by an ear, nose and throat consultant as well as a psychiatrist, the doctors concluded in a medical report that the applicant’s allegations of ill-treatment, such as post-traumatic stress, depression, marks on her feet caused by cigarette burns, and a pelvic complaint were compatible with the medical findings. The Strasbourg Court, observing that neither this report nor any relevant evidence in support of the allegations of ill-treatment had ever been conveyed to the public prosecutor, concluded that the applicant had failed to exhaust domestic remedies as required by Article 35 § 1 of the Convention.168 ii) Witnesses According to Rule 1 of the Annex to the Rules of Court: The Chamber may, inter alia, invite the parties to produce documentary evidence and decide to hear as a witness or expert or in any other capacity any person whose evidence or statements seem likely to assist it in carrying out its tasks. Other than hearing witnesses directly, the Court also accepts statements taken from any eyewitnesses or other persons whose testimonies may help it establish the facts of cases. Naturally, statements taken from such witnesses by domestic 166 For a review of the medical techniques in documenting ill-treatment, see Michael Peel and Vincent Iacopino (eds.), The Medical Documentation of Torture, Greenwich Medical Media Limited, 2002. 167 Saraç v. Turkey (dec.), no. 35841/97, 2 September 2004. 168 Ibid. 72