PART 2: How to Bring a Case to the Court he had had no experience with the police or with any other authorities before the incident. He was not therefore aware of the importance of contacting officials at once about his injuries. Although his injuries required immediate medical attention, he felt humiliated and ashamed because of the incident. Being unfamiliar with the towns which he subsequently passed through on his way home, he did not seek medical help until he returned to his home town. However, he was in constant pain throughout this period on account of the severity of his injuries.161 The respondent Government submitted, for its part, that “[d]ue to the applicant’s belatedness in seeking medical help … the medical expert … could not determine with certainty whether the applicant’s injuries had been inflicted before, during or after his interrogation”.162 The Court rejected the Government’s submissions and held that the applicant, having been interrogated in police custody on 9 August 1995, was said by his four companions to have left the police station with a red and swollen face. All these witnesses deposed, in consistent terms, that he must have been beaten […] It is true that the applicant did not seek medical help in the evening of the alleged incident or on the next day, but waited until 11 August 1995 before doing so. However, in view of the fact that the applicant immediately sought medical assistance on his arrival in his home town, the Court is reluctant to attribute any decisive importance to this delay, which, in any event, cannot be considered so significant as to undermine his case under Article 3.163 This case illustrates that independent medical reports that are corroborated by witness statements will have an even higher evidential value than medical reports standing on their own. Moreover, before relying on a medical report obtained some time after the release, the Court will take into account the degree of consistency of the applicant’s allegations and will expect the applicant to describe with a certain level of precision the causal link between the medical report and the ill-treatment. This is further illustrated in the case of Gurepka v. Ukraine164 in which the applicant submitted to the Court a medical report, drawn up six days after his release from detention, showing that the conditions of detention had had a negative effect on his health. The Court rejected the allegation as being manifestly ill-founded In so far as the applicant complains of his detention in a cold cell and his ensuing health problems allegedly caused by it, the Court finds that the applicant has failed to demonstrate that the impugned treatment, formulated by the applicant in very general terms, attained the minimum level of severity proscribed by Article 3 of the Convention, particularly in the absence of any medical or other evidence … The sick leave certificate presented by the applicant as to his illness from 7 December 1998, that is 6 days after his release, does not constitute sufficient proof of a causal link with the alleged ill-treatment.165 161 162 163 164 165 Ibid., § 37. Ibid., § 40. Ibid., §§ 48–49. Gurepka v. Ukraine, no. 61406/00, 6 September 2005. Ibid., § 35. 71