Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook give rise to similar applications before the Court.” 434 Here, the consequence of a pilot judgment may be that the Court could adjourn or “freeze” related cases for a period of time on the condition that the Government act promptly to introduce a new domestic remedy as part of the national measures required to satisfy the judgment. If the remedy is introduced and is found to be in principle suitable, the frozen applications will be declared admissible and applicants required making use of the new domestic remedy. A remedy is considered to be effective if it is capable of rendering redress for the applicant with regard to the alleged human rights violation.435 The issue of the ‘effectiveness’ of domestic remedies is examined below under separate headings for criminal, civil, and administrative remedies. i. Criminal Remedies As the Court expressly stated in the case of Akdıvar and Others v. Turkey,436 the rule of exhaustion of domestic remedies is based on the assumption, reflected in Article 13 of the Convention, that effective remedies are in fact available in the domestic systems of Contracting Parties for alleged breaches of Convention rights regardless of the specific manner in which the provisions of the Convention have been incorporated into national law. Thus, the issue of effectiveness of criminal remedies in respect of complaints of ill-treatment is closely linked to the Contracting Parties’ positive obligation under Article 3 and their obligation under Article 13 to provide an effective remedy.437 As pointed out earlier, in the context of Article 3 violations adequate redress will include an effective official investigation capable of leading to the identification and punishment of those responsible. Whereas certain rights and freedoms guaranteed in the Convention may not have been incorporated into the national laws of all Contracting Parties, most types of ill-treatment nevertheless constitute criminal offences in all Contracting Parties. Furthermore, in most Contracting Parties, ill-treatment inflicted by State agents is either classified as a criminal offence separate from the offence of ill-treatment inflicted by private persons, or is considered an aggravating element of ill-treatment offences. At first sight it would therefore appear that the national laws of the Contracting Parties themselves provide for an effective remedy – as required by Article 13 of the Convention – in respect of complaints of ill-treatment. However, the mere existence of national legislation criminalising acts of ill-treatment is not sufficient 434 Factsheet: Pilot Judgments (October 2013), p. 2, available online: http://www.echr.coe.int/Pages/ home.aspx?p=press/factsheets. 435 See e.g. Philip Leach, Taking a Case to the European Court of Human Rights, 3rd ed., Oxford University Press, 2009, p. 395. 436 Akdıvar and Others v. Turkey, no. 21893/93, 16 September 1996, § 65. 437 See sections 6.2 and 10 below. See also Buldan v. Turkey (dec.) no. 28298/95, 4 June 2002. 124