In Nepal, investigations tend to be slow and are not seen as being carried out impartially or thoroughly. Complainants are faced with a hostile reaction, ranging from deliberate inaction to outright threats and physical attacks, including further torture, also of family members. Police officers have in numerous cases refused to allow injured detainees to see a doctor, to consult a doctor in their absence or have delayed access to a doctor, resulting in the loss or lack of evidence.20 In the Philippines, torture investigations often last for several years without conclusion. In a recent case, a panel of prosecutors ruled that the Department of Justice would not carry out any further investigations into the allegations of torture pending review of the death penalty imposed on the accused in 1999 by the Supreme Court as the matter was sub judice. As a result, the investigation into this case remained pending for more than six years after the victims had initially brought a complaint against named police officers.21 The Commission on Human Rights may investigate torture cases but suffers from difficulties in obtaining access to army premises and inadequate resources. Moreover, where it has recommended prosecutions, requests have been pending with the Ombudsman or not been acted upon otherwise, resulting in further delays and ultimately lack of prosecution.22 Europe In Europe, investigations in torture cases have repeatedly suffered from delays as evidenced by cases concerning Spain23 and the jurisprudence of the European Court of Human Rights, in particular relating to violations in Russia and Turkey.24 In spite of the repeated finding of violations by the Court, the lack of prompt and expeditious investigations remains a systemic problem in many countries. Russia Police officer Aleksey Yevgenyevich Mikheyev25 was detained and questioned on 10 September 1998 by the police in Nizhny Novgorod in relation to the reported disappearance of a teenage girl whom he and his friend had met on 8 September while off duty. He was interrogated and tortured, with electric shocks administered to his ears. Unable to bear the 20 See REDRESS/Commonwealth Human Rights Initiative, Responses to Human Rights Violations, pp.47, 48 and Report by the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, Manfred Nowak: Mission to Nepal, UN Doc. E/CN.4/2006/6/Add.5, 9 January 2006, para.20, 26. 21 See for details Amnesty International, Philippines: Torture persists: appearance and reality within the criminal justice system, AI Index: ASA 35/001/2003, 24 January 2003, pp.30 et seq. 22 REDRESS, Action against Torture, A practical guide to the Istanbul Protocol for lawyers in the Philippines, November 2007, pp. 35, 36. 23 See in particular the cases decided by the Committee against Torture, Encarnacion Blanco Abad v. Spain and Henri Parot v Spain. 24 See in particular Mikheyev v. Russia and Aksoy v. Turkey, as well as further cases concerning the respective countries contained in the annexed Table of Authorities. 25 Mikheyev v. The Russian Federation, Application No.77617/01, European Court of Human Rights, Judgment of 26 January 2006. 11