The CPT recommends that the Albanian authorities take the necessary steps to ensure that at all levels of the criminal justice system – including at the sentencing stage – a firm attitude is adopted with regard to torture and other forms of ill-treatment. In the Committee’s opinion, this result can be achieved without undermining the independence of the judiciary, for example by including in initial and continuous judicial professional curricula, practical training on the role of the judiciary in the fight against impunity for ill-treatment by the police.”202 With respect to the proportionality of actual punishments applied to the perpetrators the Strasbourg Court has held that: “… the Court should grant substantial deference to the national courts in the choice of appropriate sanctions for ill‑treatment and homicide by State agents. However, it must still exercise a certain power of review and intervene in cases of manifest disproportion between the gravity of the act and the punishment imposed.”203 Moreover, in Valeriu and Nicolae Rosca v. Moldova it noted that: “. . . in the present case the three officers convicted of ill-treating the applicants were sentenced to three years’ imprisonment and disqualification from working in a law-enforcement agency for two years. That term of imprisonment was the minimum penalty allowed by law (see paragraph 37 above). It is for the domestic courts passing sentence to set the penalty which they consider is most appropriate to ensure the educational and preventive effect of the conviction. The courts did so in the present case, and explained the reason for the leniency of the sentence by reference to the accused’s relatively young age, lack of previous convictions, and the fact that they had families and were viewed positively in society (see paragraph 32 above). Under the domestic law the courts had to take into account both mitigating and aggravating circumstances. However, the courts were silent about a number of apparently applicable aggravating circumstances (expressly mentioned in Article 38 of the Criminal Code – see paragraph 37 above). In particular, none of the officers showed any signs of remorse, having denied throughout the proceedings any ill-treatment on their part. The Court also notes that even the minimum sentence imposed on the officers was suspended with one year’s probation, so that the officers did not spend any time in prison. Moreover, they were not suspended from their positions during the investigation (contrary to the recommendations of the Istanbul Protocol – see paragraph 43 above).” 202. CPT’s Report on the visit to Albania from 23 May to 3 June 2005, CPT/Inf (2006) 24, para. 54. 203. Ali and Ayşe Duran v. Turkey, Judgment of 8 April 2008, application no. 42942/02, para. 66. Effective investigation of ill-treatment – Guidelines ► Page 68