Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook as a general rule, be taken into account for the purposes of Article 35 of the Convention. The proceedings which were held to be extraordinary in Berdzenishvili were supervisory reviews of judgments which could be brought at any time after a judgment becomes enforceable, even years later. The Court considered that if the supervisory-review procedure was considered a remedy to be exhausted, the uncertainty thereby created would have rendered nugatory the six-month rule. In the light of the above, the Court held that the applicant, who had sought a supervisory review of the Supreme Court’s judgment convicting him, should have introduced his application with the Court within six months of the Supreme Court judgment.503 Thus, it is apparent that the above that the Court applies “the six-month rule autonomously and according to the facts of each individual case, so as to ensure the effective exercise of the right to individual application”.504 In addition, it is difficult to draw general uniform guidance from which a potential applicant, in the midst of exhausting a doubtful remedy, may benefit. The Court has also “refrained from indicating a specific period for establishing when an investigation has become ineffective for the purposes of assessing the date the six-month period starts to run from. The determination of such a period by the Court depends on the circumstances of each case and other factors such as the diligence and interest displayed by the applicants.” 505 Nevertheless, the Court has explained its general standards, where a death has occurred or in disappearance cases, as follows: “[A]pplicant relatives are expected to take steps to keep track of the investigation’s progress, or lack thereof, and to lodge their applications with due expedition once they are, or should have become, aware of the lack of any effective criminal investigation.” 506 However, the Court has also “refrained from indicating a specific period for establishing when an investigation has become ineffective for the purposes of assessing the date the six-month period starts to run from. The determination of such a period by the Court depends on the circumstances of each case and other factors such as the diligence and interest displayed by the applicants.”507 Berdzenishvili v. Russia (dec.), no. 31697/03, 29 January 2004. Fernandez-Molina and Others v. Spain (dec.), no. 64359/01, 8 October 2002. Dovletukayev and Others v. Russia, nos. 7821/07, 10937/10, 14046/10 and 32782/10, 24 October 2013, § 178. Bulut and Yavuz v. Turkey (dec.), no. 73065/01, 28 May 2002. See also Bayram and Yıldırım v. Turkey (dec.), no. 38587/97, 29 January 2002 [cases involving the death of victims] and Eren and Others v. Turkey (dec.), no. 42428/98, 4 July 2002, and Üçak and Kargili and Others v. Turkey (dec.), nos. 75527/01 and 11837/02, 28 March 2006 [disappearance cases]. 507 Dovletukayev and Others v. Russia, nos. 7821/07, 10937/10, 14046/10 and 32782/10, 24 October 2013, § 178. 503 504 505 506 138