of inmates. It denounces provisions that do not draw any distinction between the different categories of persons and bodies with whom the prisoners could correspond.70 The detainee must also be able to communicate with the relevant bodies without pressure or fear of retribution: “The Court reiterates that it is of the utmost importance for the effective operation of the system of individual petition instituted by Article 34 that applicants or potential applicants should be able to communicate freely with the Court without being subjected to any form of pressure from the authorities to withdraw or modify their complaints […] In this context, “pressure” includes not only direct coercion and flagrant acts of intimidation but also other improper indirect acts or contacts designed to dissuade or discourage applicants from pursuing a Convention remedy […].”71 The CPT’s visit reports have emphasised that individuals must be able to correspond confidentially with international bodies.”72 2.3.7 Where requested, public authorities should be required to register all representations which could be deemed to constitute complaints. An appropriate form should be introduced for acknowledging receipt of each complaint and confirming that the matter will be pursued. The CPT has proposed additional safeguards to ensure that all allegations and information regarding ill-treatment reach the appropriate, competent authorities: “Apart from the possibility for persons to lodge complaints directly with the agency, it should be mandatory for public authorities such as the police to register 70. Niedbala v. Poland, Judgment of 4 July 2000, application no. 27915/95, para. 81. 71. Popov v. Russia, Judgment of 13 July 2006, application no. 26853/04, paras. 246-247. 72. CPT’s Report on the visit to Ukraine carried out from 9 to 21 October 2005, CPT/Inf (2007) 22, para. 151. With specific reference to police detention, the CEHRC has enumerated the different ways in which information regarding ill-treatment may be communicated, but fails to describe how these methods may be secured: “Access to the police complaints system, either by the complainant or his or her nominated representative, may be by a number of methods, including: in person at police premises, either on the occasion that gave rise to the complaint or subsequently; by telephone call to the police or IPCB; by facsimile to the police or IPCB; by letter to the police or IPCB; or electronically, by email or the World Wide Web, to the police or IPCB.” Opinion of the Council of Europe’s Commissioner for Human Rights, Thomas Hammarberg, concerning independent and effective determination of complaints against the police, CommDH(2009)4, para. 46. Hereinafter referred to as “the CEHRC’s Opinion.” Effective investigation of ill-treatment – Guidelines ► Page 36