Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook and undertook to issue appropriate instructions and adopt all necessary measures to ensure that the prohibition of such forms of ill-treatment – including the obligation to carry out effective investigations – is respected in the future.239 Governments may be willing to settle cases for a number of reasons. For example, they may wish to settle a case in which complaints are based on national legislation which the Court has previously identified as incompatible with the Convention or which the respondent Contracting Party has itself acknowledged is incompatible with the Convention. For example, in the case of Zarakolu v. Turkey, the applicant, owner of a publishing company, was convicted under the Prevention of Terrorism Act for having disseminated propaganda in support of a terrorist organization in a book published by her company. The application lodged by the applicant was struck out of the Court’s list of cases as the parties subsequently reached a settlement on the basis of a declaration made by the Turkish Government which included, inter alia, the following acknowledgement: The Government note that the Court’s rulings against Turkey in cases involving prosecutions under the provisions of the Prevention of Terrorism Act relating to freedom of expression show that Turkish law and practice urgently need to be brought into line with the Convention’s requirements under Article 10 of the Convention. This is also reflected in the interference underlying the facts of the present case. The Government undertake to this end to implement all necessary reform of domestic law and practice in this area, as already outlined in the National Programme of 24 March 2001.240 As pointed out above, friendly settlement declarations may include terms pursuant to which a respondent Government may undertake specific action to resolve the issue. For example, the case of K.K.C. v. the Netherlands, which concerned the intended expulsion of the applicant – a Russian national of Chechen origin – to Russia, where the applicant argued there was a real risk he would be subjected to treatment contrary to Article 3 of the Convention, was struck out on the basis of the settlement reached between the parties. Pursuant to the terms of the declaration, the respondent Government undertook to issue the applicant a residence permit without restrictions.241 Parties are expected to stipulate in their respective declarations that the settlement will constitute the final resolution of the case and that they will not request the referral of the case to the Grand Chamber under Article 43 § 1 of the Convention.242 239 240 241 242 88 Ibid. Zarakolu v. Turkey, no. 32455/96, 27 May 2003, § 19. K.K.C. v. the Netherlands, no. 58964/00, 21 December 2001, § 26. See section 2.1.22.