the right to have a third party informed of arrest and the right to be notified of one’s rights.23 Laws and measures relevant to the admissibility of confession evidence 14. OSCE participating States employ a variety of safeguards to ensure that confessions are not made as a result of torture or other ill-treatment. Of the 13 countries surveyed, for example, only three permit confessions to be the sole evidence of guilt.24 In this context, the Supreme Court in one of these states has ruled that the parliament should review the relevant law. The case referred to a previous conviction of a woman with an intellectual disability, based solely on her confession, which was obtained without a lawyer present and with no corroborating evidence.25 Outside of the countries surveyed, many of the OSCE countries that allow confessions to be the sole evidence of guilt are located in Western Europe, although these employ some form of additional safeguard (outlined below).26 15. Examples of measures designed to eliminate the use of confessions as the sole evidence of guilt from countries across the OSCE include: a. Corroborating evidence: Many OSCE countries require corroborating evidence in addition to a confession.27 b. Types of confession: Some countries distinguish between confessions, based on the stage of proceedings in which they were given, or to which actors in the justice system they were given. In one Western European state, for example, confessions made before a judge can be relied on as the sole evidence of guilt, provided certain conditions are met,28 but confessions made before a police of- 23 24 25 26 27 28 16 International Covenant on Civil and Political Rights, (1976) Article 14; see also the EU Roadmap for strengthening procedural rights of suspected or accused persons in criminal proceedings outlined at: European Commission, “Rights of suspects and accused”, (2019). Questionnaire responses CSOs (North Macedonia, Poland and Serbia) (2019). Supreme Court of Poland, judgment of 23 June 2016 (case no. II KK 39/16). Fair Trials and REDRESS, “Tainted by Torture: Examining the Use of Torture Evidence”, (2018), p. 46–47. This includes but is not limited to Armenia, Georgia, Hungary, Kyrgyzstan, Moldova, Romania, Russia, Turkey, Ukraine and the United States, Questionnaire responses (2019); Kenneth S. Broun et al., ‘McCormick on Evidence, 7th edition, June 2016 update, para. 145. Judgment of the Spanish Supreme Court, 307/2008 of 5 June 2008.