Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook c) Enforcement According to Article 46 § 1 of the Convention, Contracting Parties undertake to abide by the final judgment of the Court in any case to which they are parties. This also applies to friendly settlements. Furthermore, paragraph 2 of the same provision stipulates that final judgments of the Court shall be transmitted to the Committee of Ministers which will supervise their execution. It follows, therefore, that the Committee of Ministers is responsible for the supervision of a judgment in which the case was struck out on the basis of a friendly settlement. In case of a failure by the respondent Government to uphold the terms of its friendly settlement declaration, applicants may seek assistance from the Committee of Ministers. d) Friendly Settlements in Article 3 Cases Friendly settlements in cases involving serious human rights violations, such as the prohibition of torture, inhuman or degrading treatment or the right to life are not uncontroversial. However, friendly settlements afford the Court an opportunity to clear up its docket in order to focus on cases that justify merits decisions. In addition, the friendly settlement procedure is considerably shorter than a regular procedure. An analysis of the Court’s decisions that have been struck out on the basis of a friendly settlement shows that they involve minor violations of Article 3 of the Convention. Most such decisions concern the conditions of detention or other issues where there exists well-established case law. The damages awarded often range between 1000 and 6000 euros. In addition, friendly settlements are often concluded after there has been a pilot judgment. For instance, the pilot judgment in the case of Orchowski v. Poland,244 condemning the serious and chronic overcrowding of Polish prisons, resulted in dozens of friendly settlements.245 If a friendly settlement is proposed by the parties, the Court has powers to review the conditions of the settlement and may refuse to strike a case out if it considers that respect for human rights as defined in the Convention and the Protocols requires an examination on the merits. It is also important to note that the applicant may negotiate with the respondent Government to obtain specific undertakings, such as an undertaking to carry out an effective investigation into his or her allegations of ill-treatment. If the respondent Government refuses to carry out such an investigation as part of the friendly settlement agreement, the applicant may argue that striking the case out solely on the basis of monetary payment represents 244 Orchowski v. Poland, no.17885/04, 22 October 2009. 245 See e.g. Mech v. Poland (dec.), no. 55354/12, 4 February 2014; Siwiak v. Poland (dec.), no. 18250/13, 4 February 2014; Walczyk v. Poland (dec.), no. 74907/11, 15 October 2013; Gołek v. Poland (dec.), no. 25024/09, 1 October 2013. 90