4.2.2 The typical inventory of required investigative measures and evidence includes: The list of basic investigative measures set out in the Guidelines is illustrative. It is based on typical examples contained in the case law of the Strasbourg Court and CPT’s visit reports. ff detailed and exhaustive statements of alleged victims obtained with an appropriate degree of sensitivity; In many cases, the testimony of victims is either not obtained at all or the authorities fail to seek clarification on certain points that are crucial in the circumstances. Such failures have led to criticism by the Strasbourg Court: “It is also noteworthy that the applicant himself was never questioned about the origin of his bruises, either when allegations were made that it was Crinel M. who had beaten him up, or after he had complained to the prosecutor that it was the police who had beaten him up. Similarly, none of the police officers who had declared that the applicant had bruises upon his arrival at the police station was asked to explain why he had not been questioned about the origin of his bruises either on his arrival at the police station on 4 July 1997 or later, when they learned that he had been admitted to hospital. No explanation was provided by the authorities as to why no steps had been taken to investigate his alleged beating by Crinel M.”118 The vulnerability of victims of psychological ill-treatment necessitates in particular that they are questioned with specific care. The Istanbul Protocol sets out detailed considerations in this regard.119 ff appropriate questioning and, where necessary, the use of identification parades and other special investigative measures designed to identify those responsible; Genuine efforts to identify and question the alleged perpetrators are other indispensable elements of all investigations on ill-treatment. In its case law, the Strasbourg Court has identified many shortcomings in this regard: “The Court finds it particularly striking that although the applicant repeated on 9 March 1995 that he would be able to recognise the warders concerned if he could see them in person, nothing was done to enable him to do so and, just nine days later, the public prosecutor’s office sought and was granted an order 118. Cobzaru v. Romania, Judgment of 26 July 2007, application no. 48254/99, para. 71. 119. Istanbul Protocol, paras 120-160. As to additional measures for victims’ protection see Guidelines 4.4.3, 4.4.4 and related comments below. Explanatory note ► Page 47