The court went on to describe the content of this obligation, which merely requires the state to do what is reasonable to uncover a discriminatory motive. The Court also held that failure to hold an adequate investigation into ill-treatment potentially involving discrimination can itself constitute a substantive violation of Article 14 of the ECHR. 93 3.1.4 Investigations into ill-treatment which do not fall into the mandatory categories must meet the same standards on effectiveness. The case-law of the Strasbourg Court and other mechanisms suggests that not all kinds of ill-treatment prohibited by Article 3 give rise to the obligation to investigate. However, formal investigations can also be carried out into inadequate detention conditions or medical treatment or other apparently less serious violations of the prohibition of ill-treatment. Once these are initiated, they must meet the same standards as those required of mandatory investigations. The inclusion of this Guideline is the result of the evidential value that the Strasbourg Court attaches to such “non-obligatory” investigations, which is illustrated by its assessment of the adequacy of the investigation on conditions of detention referred to below: “Most of the Government’s arguments are based on the results of the internal criminal investigation, to the effect that the first applicant’s complaints about the conditions in the punishment were untrue. However, the Court is not convinced by that conclusion. First, the investigation cannot be considered to have been effective because it was launched only four months after the first applicant complained to the prosecution authorities, thus giving the prison administration sufficient time to renovate the cell in question. Secondly, the investigation could not reasonably be considered to have been objective, in so far as it was conducted without the participation of the first applicant’s advocates, and its conclusions were mostly based on the statements of the prison administration complained of (see, amongst many others, Gharibashvili v. Georgia, no. 11830/03, §§ 60-63, 29 July 2008; Barbu Anghelescu v. Romania, no. 46430/99, § 66, 5 October 2004; Corsacov v. Moldova, no. 18944/02, § 70, 4 April 2006).”94 It remains to be seen whether the Court will extend the mandatory obligation to investigate to cover allegations of inadequate detention conditions.95 93. See also Cobzaru v. Romania, Judgment of 26 July 2007, application no. 48254/99, paras. 96-101. 94. Ramishvili and Kokhreidze v. Georgia, Judgment of 27 January 2009, application no. 1704/06, para. 80. 95. See Fedotov v. Russia, Judgment of 25 October 2005, application no. 5140/02, paras. 63, 69-70. Explanatory note ► Page 41