3.1.2 It is mandatory to conduct an investigation when confronted with credible accounts of physical or psychological abuse, excessive use of force, or other forms of serious (deliberate) ill-treatment. At the initial stages of determination of relevant accounts it is difficult to decide on the definitional thresholds and differences between torture and other forms of ill-treatment.82 Moreover, it is not only a high degree of physical or psychological harm that matters in this regard and engages the obligation to investigate.83 That is why there exists no exhaustive list of situations and indications giving rise to this duty.84 In view of the potential variables that might exist from one case to the next, the Guidelines follow the Court that operates for this purpose with the term “seriousness” of ill-treatment. “The Court reiterates that where an individual raises an arguable claim that he or she has been seriously ill-treated by the police in breach of Article 3, that provision, read in conjunction with the State’s general duty under Article 1 of the Convention to “secure to everyone within their jurisdiction the rights and freedoms defined in ... [the] Convention”, requires by implication that there should be an effective official investigation.”85 The case law of the Court is, however, illustrative of the main scenarios that lead to the obligation to investigate. First, it arises in respect of physical or psychological abuse, assaults and other forms of deliberate ill-treatment.86 The level of diversity of particular circumstances that result in corresponding violations of Article 3 of the ECHR can be illustrated by the suffering caused to next of kin by the mutilation of loved ones who have been killed.87 As the material scope of the prohibition of torture and other ill-treatment widens, so too does the range of circumstances in which the obligation to investigate arises. Thus, it has been considered to flow from the intentional destruction of homes and possessions. 82. See General Comment N2, CAT/C/GC/2, para. 3. 83. See A. Reidy, The Prohibition of Torture. A Guide to the Implementation of Article 3 of the European Convention on Human Rights. Human rights handbooks, No. 6, Council of Europe, 2002. Due to the specific rationale, accents and scope of the Guidelines they do not deal with the definitions and classifications of substantial violations of the prohibition. Hence, the same approach is used in the ECHRC’s Opinion. 84. See the comments on Guideline V.1.1. 85. Maslova and Nalbandov v. Russia, Judgment of 24 January 2008, application no. 839/02, para. 91. 86. Maslova and Nalbandov v. Russia, Judgment of 24 January 2008, application no. 839/02, para. 91. 87. Akkum v. Turkey, Judgment of 24 March 2005, application no. 21894/93, paras. 259, 265. Explanatory note ► Page 39