insufficient to ensure the preventive effect of the legislation passed specifically to address the problem of ill-treatment.”199 The rationale of the relevant move and direction in which the case law of the Strasbourg Court is moving can be further illustrated by the following deliberations from its judgment in Paduret v. Moldova: “The Court notes with great concern the Government’s assertion that in Moldova torture was considered an “average-level crime”, to be distinguished from more serious forms of crime and thus warranting reduced sentences (see paragraph 58 above). Such a position is absolutely incompatible with the obligations resulting from Article 3 of the Convention, given the extreme seriousness of the crime of torture. Together with the other shortcomings . . . this confirms the failure of the Moldovan authorities to fully denounce the practice of ill-treatment by the law-enforcement agencies and ads to the impression that the legislation adopted to prevent and punish acts of ill-treatment is not given full preventive effect. This conclusion is reinforced by the fact that A.P. continues to work for the police and by the very small amount of damages which he has had to pay, in instalments, despite the lack of any evidence that the bailiff attempted to find any property which A.P. may own. As such, the case gives the impression not of preventing any future similar violations, but of being an example of virtually total impunity for ill-treatment by the law-enforcement agencies.”200 The CPT’s view on these matters is as follows: “41. It is axiomatic that no matter how effective an investigation may be, it will be of little avail if the sanctions imposed for ill-treatment are inadequate. When ill-treatment has been proven, the imposition of a suitable penalty should follow. This will have a very strong dissuasive effect. Conversely, the imposition of light sentences can only engender a climate of impunity. Of course, judicial authorities are independent, and hence free to fix, within the parameters set by law, the sentence in any given case. However, via those parameters, the intent of the legislator must be clear: that the criminal justice system should adopt a firm attitude with regard to torture and other forms of ill-treatment. Similarly, sanctions imposed following the determination of disciplinary culpability should be commensurate to the gravity of the case.”201 The CPT’s approach is based on the findings contained in its visit reports: 54. Information gathered during the visit shows that in the very low number of cases that have resulted in convictions, the sentences imposed were mostly fines or, in exceptional cases, a very short term of imprisonment […] 199. Ibid., para. 74. 200. Paduret v. Moldova, ECtHR judgment of 5 January 2010, para.77. 201. 14th General Report on the CPT’s activities, CPT/Inf (2004) 28, para. 44. Explanatory note ► Page 67