PART B – International standards in the Istanbul Protocol Civil and Political Rights84 as has the European Court of Human Rights.85 The treaty bodies have approached the issue of impartiality by considering both procedural and institutional aspects. Impartiality may relate to the proceedings or delibera86 tions of the investigating body, or in respect of any suspicion of, or apparent bias 87 that may arise from conflicts of interest. In its consideration of State party reports, the UN Committee against Torture criticised the absence of independent bodies to investigate torture, particularly in respect of torture by the police, the institution that ordinarily would be tasked with investigating torture.88 Similarly, in a number of its concluding observations on State party reports, the UN Human Rights Committee expressed concern about the lack of impartial investigations of torture complaints, including the absence of independent oversight mechanisms, and urged States parties to establish independent bodies competent to receive, investigate and adjudicate all complaints on torture and ill-treatment.89 The European Court of Human Rights, when assessing the effectiveness of investigations, has often held that investigations lacked independence, e.g. where members of the same division or detachment as those implicated in the allegations were undertaking the in90 vestigation. Furthermore, the Court has noted that independence means not only a lack of hierarchical or institutional connection, but also practical independence.91 The Inter-American Commission on Human Rights has also observed that the lack of independence negatively impacts on impartiality, which is a minimum requirement for any investigation process,92 and this approach has been confirmed in the jurisprudence of the Inter-American Court.93 The European Committee for the Prevention of Torture has repeatedly stressed the importance of impartial and independent investi- 25 gations as one of the means of strengthening the protection of detainees from torture and inhuman treatment. As noted following its visit to Cyprus in 2000 “[…]it is axiomatic that the investigations conducted into such cases [torture] should not only be, but also be seen 94 to be, totally independent and impartial.” It further observed, in relation to Spain “[…] that the investigation of complaints by the internal accountability mechanisms of the National Police and the Civil Guard cannot be said to be independent and impartial”95 and emphasised “[…]that it is indispensable that the persons responsible for carrying out investigations into complaints against the police should be truly independent from those implicated in the events.”96 3. EFFECTIVE INVESTIGATIONS SHOULD BE CONDUCTED “THOROUGHLY”: SUBSTANCE OF INVESTIGATIONS There is ample jurisprudence to indicate that investigations must be “thorough” and “effective”. Whereas the term “thorough” generally relates to the scope and nature of the steps taken in carrying out an investigation, “effective” relates to the quality of the investigation. The UN Committee against Torture observed that investigations must be effective and 97 thorough, and that investigations must seek to ascertain the facts and establish the identity of any alleged perpetrators.98 The UN Human Rights Committee has consistently held that States have a duty to investigate cases of torture and disappearances thoroughly.99 The European Court of Human Rights held that a thorough investigation should be capable of leading to the identification and punishment of those responsible for any ill treatment and that it “must be ‘effective’ in practice as well as in law, in particular in the