While the civil courts have the capacity to make an independent assessment of fact, in practice the weight attached to a preceding criminal inquiry is so important that even the most convincing evidence to the contrary furnished by a plaintiff would often be discarded and such a remedy would prove to be only theoretical and illusory (see Menesheva v. Russia, no. 59261/00, § 77, 9 March 2006, and Corsacov v. Moldova, no. 18944/02, § 82, 4 April 2006) […] The Court can therefore conclude that, in the particular circumstances of the case, the possibility of suing the police for damages is merely theoretical.”30 The international standards point to a range of components of the obligation to effectively investigate allegations of ill-treatment. In addition to the requirement of adequacy of investigations, it includes measures that secure the avenues through which investigations can be initiated and appropriate punishment of the perpetrators. In comparison to the narrow understanding of the duty to investigate contained in some instruments,31 the application of a broader interpretation32 necessitates a high degree of consistency in discharging the duty, with the overarching aim of excluding impunity for illtreatment. This need for consistency is taken into account by the CPT when preparing recommendations following its visits.33 The obligation to eradicate impunity for serious human rights violations has been recently reinforced by the Guidelines of the Committee of Ministers of the Council of Europe of 30 March 2011. The first substantial chapter of the Guidelines reads: “I. The need to combat impunity 1. These guidelines address the problem of impunity in respect of serious human rights violations. Impunity arises where those responsible for acts that amount to serious human rights violations are not brought to account. 2. When it occurs, impunity is caused or facilitated notably by the lack of diligent reaction of institutions or state agents to serious human rights violations. In these circumstances, faults might be observed within state institutions, as well as at each stage of the judicial or administrative proceedings. 30. Cobzaru v. Romania, Judgment of 26 July 2007, application no. 48254/99, para. 83. 31. See the Istanbul Protocol and the Istanbul Principles, which consider an investigation into torture or other ill-treatment to be simply aiding prosecution or disciplinary sanctions (para. 78 of the Istanbul Protocol). The narrow understanding has its justification for the purposes of focusing on investigative techniques and methodologies. 32. As seen in the Court’s Judgments and in CPT guidance. 33. See the CPT’s Report on the visit to Albania from 23 May to 3 June 2005, CPT/Inf (2006) 24, paras.19-55. Effective investigation of ill-treatment – Guidelines ► Page 24