in dealing with cases against the alleged victims while also being responsible for investigating their alleged ill-treatment: “[The Court] is struck by the fact that the expert examination on 9 August 2001 was ordered by the same police investigator, Ms Z., who had questioned the applicant after his arrest and could have witnessed the alleged beatings . . .”114 The CPT has similarly highlighted that “a conflict of interest may occur when an investigation into suspected ill-treatment is dealt with in the framework of the same criminal investigation of the person alleging ill-treatment.”115 4.2 Thoroughness 4.2.1 Investigations on ill-treatment should include all reasonable steps to secure evidence concerning the relevant incident(s). Creating an exhaustive list of investigative steps needed for meeting the criterion of thoroughness is not possible. However, the Strasbourg Court has developed a general requirement of taking “all reasonable steps” or making genuine efforts. In its judgments, it often sets out an illustrative and nonexhaustive inventory of measures expected to be carried out: “The authorities must take whatever reasonable steps they can to secure the evidence concerning the incident, including, inter alia, a detailed statement concerning the allegations from the alleged victim, eyewitness testimony, forensic evidence and, where appropriate, additional medical certificates apt to provide a full and accurate record of the injuries and an objective analysis of the medical findings, in particular as regards the cause of the injuries. Any deficiency in the investigation which undermines its ability to establish the cause of injury or the person responsible will risk falling foul of this standard.”116 Other international instruments comment generally on the measures that are usually expected.117 114. Barabanshchikov v. Russia, Judgment of 8 January 2009, application no. 36220/02, para. 48. See also Toteva v. Bulgaria, Judgment of 19 May 2004, application no. 42027/98, para. 63; Grimalovs v. Latvia, Judgment of 25 June 2013, application no. 6087/03, para. 114. 115. CPT’s Report on the visit to Albania carried out from 23 May to 3 June 2005, CPT/Inf (2006) 24, para. 50. 116. Bati and Others v. Turkey, Judgment of 3 June 2004, applications nos. 33097/96 and 57834/00, para. 134. 117. Istanbul Protocol, paras. 88-106; the CEHRC’s Opinion, para. 69; 14th General Report on the CPT’s activities, CPT/Inf (2004) 28 para. 33. Effective investigation of ill-treatment – Guidelines ► Page 46