torture, Mikheyev tried to jump out of the window and broke his spine in the process. On the same day, the supposedly disappeared girl returned home unharmed. Between September 1998 and 2005, investigations were opened, discontinued and reopened more than fifteen times after repeated decisions by various supervising prosecutors and district courts. Most of these investigations were short. In several cases they were carried out by the same investigators, and tended to rely on the findings and line of inquiry of earlier investigations. It was only due to the persistence of Mikheyev and the NGO Nizhny Novgorod Committee against Torture working on his behalf, which had submitted his case to the European Court of Human Rights in November 2001 that the authorities proceeded with the case and finally brought charges against two individuals in 2005. During the trial, the Court for the first time sought to assess comprehensively all the available evidence, including expert testimony. On 30 November 2005, two officers were found guilty of abuse of office and sentenced to four years imprisonment. The European Court of Human Rights found that Russia had violated Articles 3 and 13 of the European Convention on Human Rights. In examining the investigations, it found, inter alia, that: “(para.113) … A number of investigative measures were taken very belatedly; (para.114) Not until 2000, following the transfer of the case file to another investigator, did the investigation move forward and new arguments and information appear in the investigator’s decision. However, precious time had been lost, and in the Court’s view, this could but not have a negative impact on the success of the investigation; (para.120) The Court emphasises furthermore that the case did not reach the trial stage until seven years after the events complained of. The pre-trial investigation was closed and then re-opened more than fifteen times, and it is clear that during certain periods the investigative process was no more than a formality with a predictable outcome….; (para.121) In the light of the very serious shortcomings identified above, especially during the course of the investigation, the Court concludes that it was not adequate or sufficiently effective. The Court thus dismissed the Government’s objection based on non-exhaustion of domestic remedies and holds that there has been a violation of Article 3 of the Convention under its procedural limb in that the investigation into the alleged ill-treatment was ineffective.” The judgment of the European Court of Human Rights has not changed torture investigations in Russia. Investigations continue to be delayed and ineffective as a result of procedural circularities. Complaints about torture are regularly met with a hostile reaction by the police or inspection authorities that have in several reported cases failed to register the complaints or not acted upon them. If an investigation is opened, it is often delayed by several days if not weeks. The measures taken by the police and prosecution are often cursory. The Prokuratura has apparently limited its investigations to requesting information from the superior of the suspect and, when a general reply is made that no torture or ill-treatment had been committed, it is decided to close the case. Cases have been closed without victims being questioned and sometimes even in spite of available evidence indicating the commission of torture. In the face of a deficient practice of securing medical evidence, torture 12

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