In the majority of judgments the Court was able to determine a lack of independence from a brief analysis of the institutional hierarchies comprising investigative bodies. For example, in Rehbock, it noted that: “The investigation was carried out within the Slovenj Gradec Police Administration the members of which had been involved in the applicant’s arrest.”106 Moreover, in its recent judgments the Court has consolidated the standard and suggested: “What is important is that the investigation of alleged misconduct potentially engaging the responsibility of a public authority and its officers was carried out by those agents’ colleagues, employed by the same public authority.”107 The Court’s findings of a lack of independence on the part of the investigating authorities have led to changes in domestic systems, of which the Dutch reforms are one of good examples.108 4.1.2 This requires independence in practical terms, not only the absence of hierarchical or institutional connections. The analysis will often go further and examine whether independence exists in practical terms: “In this context, it is recalled that the Kulp District Governor appointed the Kulp District Gendarme Commander, who was the hierarchical superior of the gendarmes who were allegedly involved in the incident, as investigating officer. It is also clear from the witness testimonies that the Kulp District Gendarme Commander further delegated the Kulp Gendarme Station Commander to conduct the investigation. In view of the fact that the Kulp Gendarmerie was allegedly accused of being involved in the burning of the applicant’s house, the Court finds it unacceptable that the same gendarme station was delegated to conduct an investigation into the allegations.”109 106. Rehbock v. Slovenia, Judgment of 28 November 2000, application no. 29462/95, para. 74. See also Mikheev v. Russia, Judgment of 26 January 2006, application no. 77617/01, para. 115. Đurđević v. Croatiav, Judgment of 19 July 2011, application no, 52442/09 para. 87. 107. Najafli v. Azerbaijan, Judgment of 2 October 2012, application no. 2594/07, para. 51. See also Taraburca v. Moldova, Judgment of 6 December 2011, application no. 18919/10, para. 54. 108. See Ramsahai and Others v. the Netherlands, Judgment of 15 May 2007, application no. 52391/99, paras. 258-267. On some other models and systems introduced in different jurisdictions see below the comments to guideline 5.2.2. 109. See Altun v. Turkey, Judgment of 1 June 2004, application no. 24561/94, para. 74. Effective investigation of ill-treatment – Guidelines ► Page 44