ANGUELOVA v. BULGARIA JUDGMENT 27 Furthermore, this allegedly reflected a broader pattern that had been noted by international organisations. The applicant referred to the Report of the Special Rapporteur on Torture to the United Nations Commission on Human Rights (Document E/CN.4/1997/7 of 10 January 1997), which stated at p. 9: “The Special Rapporteur is concerned by the frequency of allegations of torture or ill-treatment, sometimes followed by death, of persons in police custody [in Bulgaria]. The rarity of any disciplinary measures and of investigations leading to criminal prosecutions, as well as the virtual absence of successful prosecutions of those responsible, can only lead to a climate of impunity. He believes the Government should establish measures to ensure the independent monitoring, on a sustained basis, of the arrest, detention, and interrogation practices of the relevant law enforcement agencies.” 134. The applicant lastly alleged that she had on several occasions been misinformed by the authorities about the course of the investigation and its findings and had not been given full access to the case file before February 1997, more than a year after her son's death. 135. The Government asserted that the investigation had been prompt and thorough, referring to the numerous interrogations, expert reports and other investigative measures. The applicant had been provided with an opportunity to consult the case file and to submit appeals and requests for further investigation. Her request for an exhumation had rightly been refused as it had been clearly established that Mr Zabchekov's ribs had been intact. 2. The Court's assessment (a) General principles 136. The Court reiterates that the obligation to protect the right to life under Article 2 of the Convention, read in conjunction with the State's general duty under Article 1 of the Convention to “secure to everyone within [its] jurisdiction the rights and freedoms defined in [the] Convention”, requires by implication that there should be some form of effective official investigation when individuals have been killed as a result of the use of force. The investigation must be, inter alia, thorough, impartial and careful (see McCann and Others, cited above, p. 49, §§ 161-63; Kaya v. Turkey, judgment of 19 February 1998, Reports of Judgments and Decisions 1998-I, p. 329, § 105; and Çakıcı v. Turkey [GC], no. 23657/94, § 86, ECHR 1999-IV). 137. The essential purpose of such an investigation is to secure the effective implementation of the domestic laws which protect the right to life and, in those cases involving State agents or bodies, to ensure their accountability for deaths occurring under their responsibility (see, for