Explanatory Note Legal basis T he Guidelines incorporate international standards set out in the ECHR, growing case law of the Strasbourg Court and in other international instruments. They are therefore important in terms of their capacity to assist states in avoiding adverse judgments for failure to fulfil the procedural obligations to effectively investigate ill-treatment cases. Using the case law of the Strasbourg Court as a source of guidance, the CPT has expanded the scope of both its fact-finding activities and its recommendations relating to investigations into ill-treatment. The CPT standards are set out in its 14th General Report.9 Most recently they have been supplemented by the substantial section of the 23rd General Report entitled “Documenting and reporting medical evidence of ill-treatment”.10 Due to their evidential value and significance as indicators of commonly accepted approaches, the CPT’s findings and standards are now referred to in the majority of the Court’s judgments in cases related to the rights of persons deprived of their liberty.11 However, the importance of the CPT’s work goes further than this. Due to the power of the CPT’s recommendations, its ex officio visits across Member States, and its power to control implementation, it is playing a standard-setting, quasi-legislative role. Its requirements have therefore attained considerable significance for the protection of the human rights of persons deprived of their liberty. 9. See the section entitled, “Combating Impunity” [CPT/Inf92006) 28] appended to the current publication. 10. CPT/Inf (2013) 29, paras. 71-84. See appendix 6 of the current publication. 11. See among other cases Kalashnikov v. Russia, no. 47095/99, Judgment, 15 July 2002, para. 97; Fedotov v. Russia, Judgment of 25 October 2005, application no. 5140/02, paras. 54-55; Mammadov (Jalaloglu) v. Azerbaijan, Judgment of 11 January 2007, application no. 34445/04, paras. 38-39; Ramishvili and Kokhreidze v. Georgia, Judgment of 27 January 2009, application no. 1704/06, para. 70. ► Page 17