Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook are not generally considered “effective” for purposes of Article 3 and do not need to be exhausted.424 It is noteworthy that the Court on occasion refuses to deal with State’s assertions that remedies had not been exhausted where issues are closely related to the merits of an Article 3 complaint. It said, for instance, in the case of Baklanov v. Ukraine concerning alleged hazing in the Ukrainian army that caused mental disability: [T]he issue of exhaustion of domestic remedies is closely linked to the merits of the applicant’s complaint under the procedural limb of Article 3 of the Convention regarding the effectiveness of the domestic investigation into his complaint of ill-treatment. The Court therefore joins the Government’s objection to the merits of the aforementioned complaint. The Court also considers that this complaint raises serious issues of fact and law under the Convention, the determination of which requires an examination of the merits.425 In principle, applicants are not required to pursue multiple parallel remedies, should they be available. The Court has held that “when a remedy has been pursued, use of another remedy which has essentially the same objective is not required.”426 As a procedural matter, the applicant has the initial burden of proving exhaustion. In fact, the Court will examine the issue of exhaustion ex officio in its first examination of the complaint on the basis of the application form. It is therefore imperative that the applicant demonstrates clearly, in the application form, that he or she has exhausted the relevant domestic remedies in relation to the complaints made. A failure to show exhaustion, or to explain why a nominally available remedy was not pursued, will most likely result in the complaint being declared inadmissible by a Committee or Single Judge. If the Court is satisfied that an applicant has made a prima facie case showing that he or she has complied with the exhaustion requirement, then the burden shifts to the Contracting Party to show that an effective remedy was available and not exhausted by the applicant.427 The applicant will then have the opportunity to comment further on the respondent Government’s submission. After the admissibility of the application has been considered, the Government is estopped from making further arguments on exhaustion or any other admissibility issues.428 A Government that for the first time raises an objection of non-exhaustion in their (additional) observations on the merits of the case 424 See Tepe v. Turkey (dec.), no. 31247/96, 22 January 2002. 425 Baklanov v. Ukraine, no. 44425/08, 24 October 2013, §§ 45–46. 426 Kozacıoğlu v. Turkey [GC], no. 2334/03, 19 February 2009, § 40; Micallef v. Malta [GC], no. 17056/06, 15 October 2009, § 58; Aquilina v. Malta [GC], no. 25642/94, 29 April 1999, § 39; and Riad and Idiab v. Belgium, nos. 29787/03 and 29810/03, 24 January 2008, § 84. 427 Akdıvar and Others v. Turkey, no. 21893/93, 16 September 1996, § 68. 428 Savitchi v. Moldova, no. 11039/02, 11 October 2005, § 28. 122