Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook of proceedings can be crucial for a restitutio in integrum.298 Thus the Committee of Ministers opined that the reopening of proceedings has proved the most efficient, if not the only, means of achieving restitutio in integrum.299 In their submission, applicants can state as to what extend domestic procedures could be re-opened and if this would constitute full redress. The Court or the Committee of Ministers could also require States to take other individual measures such as the non-enforcement of a domestic judgment, a specific treatment in prison (e.g. refrain from handcuffing300), the termination of criminal proceedings,301 the lift of a travel ban,302 the granting of permanent residence permit,303 investigations into cases of torture,304 the trial of perpetrators of torture,305 or the restitution of property.306 c) General Measures and the Pilot Judgment Procedure The Court or the Committee of Ministers may also ask the State to take general measures such as amending laws or changing practices. Usually, it is the Committee of Ministers that translates the finding of a judgment into general measures. Typical general measures are the amendment of legislation as well as the translation and the dissemination of a judgment.307 In the context of Article 3, the Committee of Minister’s Resolution on the case of Gongadze v. Ukraine308 is illustrative. 298 299 300 301 302 303 304 305 306 307 308 102 ResDH (2009) 119, 3 December 2009), San Marino (Stefanelli v. San Marino, no. 35396/97, Committee of Ministers, ResDH (2004) 4, 24 April 2004), Austria (Schelling, Birnleitner, Bakker, Abrahamian, Brugger, Emmer-Reissig and Hofbauer (No. 2) v. Austria, no. 55193/00; et al., Committee of Ministers, ResDH (2011) 187, 2 December 2011), Portugal (Panasenko, Bogumil and Czekalla v. Portugal, nos. 10418/03, 35228/03 and 38830/97), Committee of Ministers, ResDH (2011) 143, 14 September 2012), and Moldova (Metropolitan Church of Bessarabia and Others and Biserica Adevărat Ortodoxă din Moldova and Others v. Moldova, nos. 45701/99 and 952/03, Committee of Ministers, ResDH (2010) 8, 4 March 2010). Marco Borghi, “Switzerland” in Robert Blackburn and Jörg Polakiewicz (eds), Fundamental Rights in Europe. The European Convention on Human Rights and its Member States, 1950–2000, Oxford University Press, 2001, p. 876. Committee of Ministers, Recommendation Rec. (2000) 2 of the Committee of Ministers to member States on the re-examination or reopening of certain cases at domestic level following judgments of the European Court of Human Rights, 19 January 2000, available online: https://wcd.coe. int/ViewDoc.jsp?id=334147&Sector=secCM&Language=lanEnglish&Ver=original (last visited 26 November 2013). Kashavelov v. Bulgaria, no. 891/05, Committee of Ministers, ResDH (2013) 98, 6 June 2013. Yankov and 9 Others v. Bulgaria, nos. 39084/97, 47823/99, 58971/00, 57847/00, 39270/98, 42987/98, 44062/98, 74792/01, 29381/04 and 33606/05, Committee of Ministers, ResDH (2013) 102, 6 June 2013. Riener v. Bulgaria, no. 46343/99, Committee of Ministers, ResDH (2013) 100, 6 June 2013. R.C. v. Sweden, no. 41827/07, Committee of Ministers, ResDH (2013) 75, 30 April 2013. Gongadze v. Ukraine, no. 34056/02, Committee of Ministers, ResDH (2008)35, 5 June 2008. Ibid. Gladysheva v. Russia, no. 7097/10, 6 October 2011, § 106. See e.g. Gencel and 205 Other Cases v. Turkey, nos. 53431 et al., Committee of Ministers, ResDH (2013)256, 5 December 2013. Gongadze v. Ukraine, no. 34056/02, 8 November 2005.