4.5.1 Alleged victims of ill-treatment or their representatives must be involved in investigative procedures to the extent necessary to safeguard their legitimate interests. Victims should be entitled to request specific steps to be taken and to participate in specific investigative actions, where appropriate. They should be regularly informed as to the progress of investigations and all relevant decisions made. They should be provided with legal aid, if necessary, and be able to challenge actions or omissions of investigating authorities by means of a public and adversarial judicial review procedure. The involvement of the victim is not officially a fair trial guarantee under Article 6 ECHR or even under the more limited Article 5(4). However, it is required by the Guidelines to “the extent necessary to safeguard legitimate interests”. This is in line with a number of the Strasbourg Court’s judgments, including the following: “Finally, as regards involvement of the next of kin in the investigation, it is noteworthy that the applicants were not consistently kept abreast of its progress, despite their lawyer’s requests for information […]”166 “It further does not appear that either the applicants or their representatives were granted access to the materials of the investigation, or even provided with a copy of the decision of 7 January 2002.”167 The Guideline also states that victims ought to have standing to request investigative steps. This is a right derived from several judgments of the Court.168 4.5.2 In particularly serious cases, a public inquiry may be required in order to satisfy this requirement. Guideline 4.5.2 envisages serious cases of significant public interest, and reflects the position of the CPT.169 166. Ognyanova and Choban v. Bulgaria, Judgment of 23 February 2006, application no. 46317/99, para. 115. 167. Chitayev and Chitayev v. Russia, Judgment of 18 January 2007, application no. 59334/00, para. 165. See also Khadisov and Tsechoyev v. Russia, Judgment of 5 February 2009, application no. 21519/02, para. 122. See also Gharibashvili v. Georgia, Judgment of 29 July 2008, application no. 11830/03, para. 74. 168. See Slimani v. France, Judgment of 24 July 2004, application no. 57671/00, para. 49. 169. 14th General Report on the CPT’s activities, CPT/Inf (2004) 28, para. 36. Effective investigation of ill-treatment – Guidelines ► Page 58