- States’ obligation to prevent recurrence of similar ECHR violations Respondent states are also under an obligation to take general (legislative, regulatory or awarenessraising) measures to prevent similar human rights violations after an ECtHR judgment. Occasionally the ECtHR may identify the problem of ill-treatment during police interrogation as systemic at national level and provide indications/guidance concerning possible general measures to be taken by the respondent state. For example, in Kaverzin v. Ukraine (2012) the Court considered it necessary to stress that Ukraine must urgently put in place specific reforms in its legal system in order to ensure that practices of ill-treatment in custody are eradicated, that effective investigation is conducted in accordance with Article 3 of the Convention in every single case where an arguable complaint of illtreatment is raised and that any shortcomings in such investigation are effectively remedied at the domestic level (see also Kaverzin group of cases pending before the Committee of Ministers, concerning violations of Article 3). In certain countries it appears to have been considered sufficient, by the respondent states and the Committee of Ministers, to publicise and widely disseminate the ECtHR judgments to competent national authorities, given that national legislation appeared to be ECHR-compliant while the Article 6 violations seemed to be due to judicial practice (see e.g. Iordan Petrov v. Bulgaria, Gäfgen v. Germany, Jalloh v. Germany — as regards the violation of Article 3 in Jalloh, the practice of administering emetics to obtain evidence was expressly abandoned in the Länder, which had used it - Berlin, Bremen, Hamburg, Hessen and North Rhine-Westphalia —Stanimirović group of cases v. Serbia). In other countries more measures have been considered necessary. For example, in El Haski v. Belgium the Federal Prosecutor’s Office issued instructions to competent authorities in order to prevent the future use of declarations obtained under torture or through other inhuman or degrading treatment. Moreover, a new law amended the Code of Criminal Procedure explicitly proscribing use of evidence obtained irregularly, thus also indirectly excluding the evidence obtained through torture. Domestic case-law changes may also be considered able and necessary to prevent similar Convention violations. For example, in the Kitanovski group of cases v. the former Yugoslav Republic of Macedonia, the authorities have informed the Committee of Ministers about a number of Convention-compliant judgments delivered by the Supreme Court in 2009, 2013 and 2014 demonstrating that the domestic courts have a well-established and ECHR-compliant practice of excluding ill-treatment tainted evidence from criminal trials. Concluding remarks In the aforementioned major cases where the ECtHR has found violations of Article 6 ECHR, the judgments appear to have considered as root cause of the violations domestic courts’ practice concerning the exclusionary rule which was non-ECHR compliant, rather than flawed domestic legislation. Hence, the wide dissemination and publication of the ECtHR judgments and the effective alignment of domestic courts’ practice with the ECtHR case-law appears to be considered to provide, in most cases, sufficient guarantees for preventing recurrence of similar violations. 18