Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook it is equally important that the applicant has shared such evidence with the relevant domestic authorities in the context of a complaint as soon as possible after the occurrence of the ill-treatment. These issues are discussed further below in the context of the Court’s case law. As mentioned above, by far the strongest medical evidence is a medical report drawn up immediately after the period of detention during which the person was ill-treated. However, in some cases the applicant might not have been medically examined at the time of release. Furthermore, there may be problems associated with medical reports drawn up while the person is still in the custody of the State. For example, the applicant’s medical examination might have been carried out in the presence of police officers, in which case the applicant may conceivably have been too frightened to inform the doctor of the extent or cause of his or her injuries. The medical examinations and reports drawn up in the course of those examinations themselves may sometimes be very short and therefore not capable of proving or disproving the applicant’s allegations of ill-treatment.150 For example, in the case of Elçi and Others v. Turkey, the Court observed that “[t]he collective medical examination of the applicants prior to being brought before the Public Prosecutor can only be described as superficial and cursory […] The Court does not therefore attach great weight to it”.151 Similarly, in the case of Ochelkov v. Russia, the Court found a violation of Article 3 of the Convention because it was dissatisfied with the quality of the medical expert evidence collected in the proceedings. It does not escape the Court’s attention that although the investigators ordered a medical examination of the applicant in February 2003 and later interviewed the expert who had issued that report, they never asked the expert to identify the cause of the applicant’s injuries.” […] The Court therefore cannot but conclude that the investigators’ efforts were focused rather on the dismissal, in hasty and perfunctory fashion, of the applicant’s complaint than on a thorough verification of the substance of his allegations. […] The Court is thus of the view that the investigator’s inertia and reluctance to look for corroborating evidence precluded the creation of an accurate, reliable and precise record of the events of 14 and 15 February 2003.152 In this context, it may be useful to consult the CPT Standards on Police Custody. These standards provide, inter alia, that all medical examinations should be 150 See Camille Giffard, The Torture Reporting Handbook: How to Document and Respond to Allegations of Torture within the International System for the Protection of Human Rights, Human Rights Centre of the University of Essex, 2000. An online version of the Handbook may be consulted: http://www.essex. ac.uk/torturehandbook/handbook%28english%29.pdf. 151 Elçi and Others v. Turkey, nos. 23145/93 and 25091/94, 13 November 2003, § 642. 152 Ochelkov v. Russia, no. 17828/05, 11 April 2013, §§ 124–126. 153 European Committee for the Prevention of Torture, “Standards on Police Custody” available at http://www.cpt.coe.int/en/documents/eng-standards.doc, p. 6. 68