The Court acknowledges that this positive obligation requires legal, procedural and other measures to combat impunity: “[T]he applicants were ill-treated while in custody. However, no police officer was ever punished, either within the criminal proceedings or the internal police disciplinary procedure for ill-treating the applicants. […] It is further noted that neither Mr Tsikrikas nor Mr Avgeris were at any time suspended from service, despite the recommendation of the report on the findings of the administrative inquiry […]. In the end, the domestic court was satisfied that the applicants’ light clothing was the reason why the latter got injured during their arrest. Thus, the investigation does not appear to have produced any tangible results and the applicants received no redress for their complaints.”26 Across the Court’s judgments are a variety of different approaches to the legal characterisation of the duty to investigate. It is either classified under a combination of Articles 3 and 13,27 or simply under Article 3. While suggesting that the appropriate characterisation depends on the facts of the case,28 it seems that the Court leans towards the Article 3 approach.29 In any case, the chosen classification does not affect the essence of the obligations. It is clear from the case law, however, that the Court views compensation for damages through civil and administrative avenues as falling squarely outside the procedural head of Article 3. They are considered as a separate remedy covered by the obligations under Article 13 of the ECHR. Its effectiveness as a remedy may depend, however, on the results of the investigation: “For the reasons set out above no effective criminal investigation can be considered to have been carried out in accordance with Article 13, the requirements of which are broader than the obligation to investigate imposed by Article 3 (see mutatis mutandis, Buldan v. Turkey, no. 28298/95, § 105, 20 April 2004; Tanrıkulu v. Turkey, no. 23763/94, § 119, ECHR 1999-IV; and Tekdağ, cited above, § 98). Consequently, any other remedy available to the applicant, including a claim for damages, had limited chances of success and could be considered as theoretical and illusory, and not capable of affording redress to the applicant. 26. Bekos and Koutropoulos v. Greece, Judgment of 13December 2005, application no. 15250/02, paras. 54 and 55. 27. Çelik and İmret v. Turkey, Judgment of 26 October 2004, application no. 44093/98, paras. 54-60; Yaman v. Turkey, Judgment of 2 November 2004, application no. 32446/96, para. 49; Afanasyev v. Ukraine, Judgment of 5 April 2005, application no. 38722/02, paras. 69-70; Cobzaru v. Romania, Judgment of 26 July 2007, application no. 48254/99, paras. 80-84. 28. Bati and Others v. Turkey, Judgment of 3 June 2004, applications nos. 33097/96 and 57834/00, paras. 126-127. 29. See Assenov v. Bulgaria, Judgment of 28 October 1998, application no. 24760/94, paras. 106 and 118. Explanatory note ► Page 23