30 ANGUELOVA v. BULGARIA JUDGMENT the persons responsible. Its effectiveness cannot, therefore, be gauged on the basis of the number of reports made, witnesses questioned or other investigative measures taken. 145. The applicant alleged, in addition, that the failings of the investigation in her case were the result of a general problem of lack of independence, impartiality and public accountability on the part of the authorities handling investigations of police ill-treatment. In these particular circumstances, having already found that the investigation into the death of the applicant's son was not sufficiently objective and thorough, the Court does not need to rule on these additional aspects of her complaint. 146. The Court finds that there has been a violation of the respondent State's obligation under Article 2 § 1 of the Convention to conduct an effective investigation into the death of Mr Zabchekov. II. ALLEGED VIOLATION OF ARTICLE 3 OF THE CONVENTION 147. The applicant complained that her son had been ill-treated before his death. She relied on Article 3 of the Convention, which provides: “No one shall be subjected to torture or to inhuman or degrading treatment or punishment.” 148. The parties' submissions are summarised in paragraphs 103-08 above. 149. The Court found above that the Government had not provided a plausible explanation for the injuries to Mr Zabchekov's body. Those injuries were indicative of inhuman treatment beyond the threshold of severity required by Article 3 of the Convention. There has therefore been a violation of that provision. 150. The Court does not deem it necessary to make a separate finding under Article 3 in respect of the deficiencies in the investigation (see Mahmut Kaya v. Turkey, no. 22535/93, § 120, ECHR 2000-III), having already dealt with that question under Article 2 of the Convention (see paragraphs 132-46 above). III. ALLEGED VIOLATION OF ARTICLE 5 OF THE CONVENTION 151. Relying on Article 5 of the Convention, the applicant alleged that the detention of her son during the night of 28 to 29 January 1996 had been unlawful as there had been no lawful detention order and it had not been properly recorded. Article 5 of the Convention, in its relevant parts, provides as follows: