Under the ECtHR’s case-law, domestic courts should examine the quality of the evidence including whether the circumstances in which it was obtained cast doubt on its reliability or accuracy. Thus, the burden of proof is on the prosecution and any doubt should benefit the accused (Bokhonko v Georgia, 2020 §92). In cases where a defendant makes a prima facie case about the real evidence, forming the basis of conviction, potentially obtained through ill-treatment, national courts are under an obligation to “adequately examine” such an argument and assess the quality of the evidence (ibid. §96, see also Iordan Petrov v. Bulgaria, 2012 §140, where the ECtHR refers to the domestic courts’ obligation to carry out an “analyse approfondie” of the facts of the case if ill-treatment allegations are put forward). Also, in cases where a defendant submits that the impugned evidence emanates from torture or other forms of ill-treatment on a third person in a third state, the domestic court may not admit this evidence without having first examined the defendant’s arguments concerning it and without being satisfied that no such risk exists (El Haski v. Belgium, 2012, §§88-89). II. - Execution of ECtHR judgments concerning torture-tainted evidence States’ obligation to provide redress to victims All victims of ECHR violations should be entitled, as far as possible, to an effective restitutio in integrum. Under Recommendation No. R (2000) 2 of the Council of Europe Committee of Ministers, states’ legal systems should make it possible to re-examine a case, and reopen proceedings, following a judgment by the ECtHR finding a violation of the ECHR, “especially where: i. the injured party continues to suffer very serious negative consequences because of the outcome of the domestic decision at issue, which are not adequately remedied by the just satisfaction and cannot be rectified except by re-examination or reopening, and ii. the judgment of the Court leads to the conclusion that a. the impugned domestic decision is on the merits contrary to the Convention, or b. the violation found is based on procedural errors or shortcomings of such gravity that a serious doubt is cast on the outcome of the domestic proceedings complained of.” Thus, in cases where applicants’ convictions are found by the ECtHR to have been tainted by torture or other forms of ill-treatment, the Committee of Ministers, supervising the execution of ECtHR judgments, systematically examines whether applicants had the possibility at national level to request and obtain re-examination and reopening of their cases. For example, in El Haski v. Belgium, the applicant requested and obtained by decision of the Court of Cassation the quashing of the criminal proceedings at issue and the reopening of the trial in order to rectify the violation committed. In Iordan Petrov v. Bulgaria, in the reopened proceedings, the confessions obtained in breach of Article 3 were excluded from the case-file, the applicant’s conviction was upheld by a final judgment of the Supreme Court of Cassation and the court reduced his sentence from life imprisonment without commutation to life imprisonment. Also in some cases of the Stanimirović group of cases v. Serbia, applicants requested the reopening of the impugned criminal proceedings and in the reopened proceedings the applicants were acquitted of all charges. In the more recent case of Ćwik v. Poland, the Committee of Ministers was informed that reopening of criminal proceedings against the applicant was possible under the Code of Criminal Procedure but no request in this respect has been submitted by the applicant (see also similar situation in Hajrulahu, part of the Kitanovski group of cases v. the former Yugoslav Republic of Macedonia) 17