In Turkey, torture investigations are regularly delayed.36 Police have reportedly failed to cooperate in investigations by not disclosing custody records, which are often not produced in the first place contrary to existing regulations, shielding perpetrators or manipulating evidence, resulting in delays and the lack of evidence. Several torture cases that have come to trial were so prolonged that they were subsequently discontinued on the grounds that statutes of limitation have come to apply.37 The European Court of Human Rights has issued a series of judgments over the years detailing the lack of prompt investigations and delays in conducting proceedings.38 Latin America In many Latin American countries, torture investigations have been slow, drawn-out and inconclusive. Delays in the course of investigations are a major factor contributing to impunity as the systemic problems have not been addressed, notwithstanding a series of judgments by the Inter-American Court of Human Rights ordering states to investigate allegations of torture effectively.39 Peru Amalia Tolentino Hipolo was a young woman when, in 1994, she and her husband were stopped by a military patrol in the Huallaga region of Peru. The military conducted a series of ‘counter-subversive’ operations in this region in the context of the then conflict pitting the Fujimori Government against the Shining Path. Her husband Jesus Vera Vigilio was shot by the soldiers and Amalia Tolentino herself was gang-raped by 10-12 men. She lodged a verbal complaint with the local authorities at the time but no action was taken. It was only following a change in the regime and with the setting up of the Peruvian Truth and Reconciliation Commission, which investigated the case in 2003, that the provincial prosecutor in Aucayacu took up the case. In 2005, Amalia Tolentino provided her testimony to the Prosecutor who in turn ordered a psychological examination to be taken. The examination report found that Amalia Tolentino suffered from post traumatic stress disorder as a result of her husband’s death. However, the psychological examination did not reach any affirmative findings on the relationship between the psychological suffering and the gang-rape. No physical examination was undertaken given that more than eleven years had passed since the event. The Prosecutor did not pursue the case further on the grounds that there was insufficient evidence and that it was impossible to identify the perpetrators. The case illustrates the extraordinary obstacles that victims encounter in Peru, in particular where the violations were committed in the course of the armed conflict. A number of factors, such as the lack of resources, corruption, insufficient medico-legal expertise, high evidentiary thresholds and the lingering influence of high-ranking perpetrators, compound the difficulties already present as a result of the lengthy delays. In practice, even though there have been a few prosecutions for past violations, most of the perpetrators do not have to account for their crimes and victims face a permanent denial of justice.40 36 See for example Aydin v. Turkey, para.105 and Ilhan v. Turkey, para.100. 37 See Bati and others v. Turkey, para.145 and Human Rights Foundation of Turkey, Torture and Impunity, 2005, pp.61 et seq. 38 See the cases of Aksoy v. Turkey, Aydin v. Turkey, Bati and others v. Turkey and Ilhan v. Turkey. 39 See on the jurisprudence of the Inter-American Court of Human Rights, infra at 2.5.1. (c). 40 See the Concluding comments of the Committee on the Elimination of Discrimination against Women: Peru, UN Doc. CEDAW/C/PER/CO/6, 2 February 2007, para.20. 14