As the Court highlights, preliminary inquiries or other forms of determination of grounds for initiation of fully fledged investigations must also be viewed as part of the overall investigation and must therefore attain the relevant standards of effectiveness: “In the light of the above observations, the Court considers that the enquiries which had been relied on by the competent authorities to refuse to initiate criminal proceedings concerning the applicant’s alleged ill‑treatment in custody, manifestly lacked the required independence and thoroughness.”182 5.2.2 An independent and effective police complaints body should be set up with powers to investigate allegations of ill-treatment. Whilst the Strasbourg Court has not gone as far as to support the creation of special and independent investigative bodies into police conduct, several international instruments have done so. An example is the Istanbul Protocol: “85. In cases where involvement in torture by public officials is suspected, including possible orders for the use of torture by ministers, ministerial aides, officers acting with the knowledge of ministers, senior officers in State ministries, senior military leaders or tolerance of torture by such individuals, an objective and impartial investigation may not be possible unless a special commission of inquiry is established. A commission of inquiry may also be necessary where the expertise or the impartiality of the investigators is called into question.”183 Such bodies are expected to be independent and equipped with adequate technical and administrative personnel. They should also have access to impartial legal advice to ensure that the investigation produces admissible evidence that can be used in criminal proceedings. The full range of the Member State’s resources and authority must therefore be extended to such bodies, which must also be able to seek assistance from international legal and medical experts.184 Independent commissions can help ensure that investigations are effective from the start. They are also well-placed to ensure that disciplinary, administrative and/ or criminal measures are initiated on the basis of their findings, if appropriate.185 182. Gharibashvili v. Georgia, Judgment of 29 July 2008, application no. 11830/03, paras. 70-71. 183. Istanbul Protocol, para. 85. 184. Ibid, para. 87. 185. Ibid, para. 119. See also CEHRC’s Opinion, para. 83. Effective investigation of ill-treatment – Guidelines ► Page 62