ANGUELOVA v. BULGARIA JUDGMENT 33 159. The applicant stated that the criminal investigation had not been effective, referring to her complaints under Articles 2 and 3 of the Convention. She added that at the relevant time there had been no judicial remedy against a prosecutor's decision to discontinue criminal proceedings. 160. The Government referred to their submissions under Articles 2 and 3 and stated that the applicant could have applied to join the criminal investigation into her son's death as a private prosecutor or a civil plaintiff. 161. Article 13 of the Convention guarantees the availability at national level of a remedy to enforce the substance of the Convention rights and freedoms in whatever form they might happen to be secured in the domestic legal order. The effect of Article 13 is thus to require the provision of a domestic remedy to deal with the substance of an “arguable complaint” under the Convention and to grant appropriate relief, although Contracting States are afforded some discretion as to the manner in which they conform to their Convention obligations under this provision. The scope of the obligation under Article 13 varies depending on the nature of the applicant's complaint under the Convention. Nevertheless, the remedy required by Article 13 must be “effective” in practice as well as in law. Where an arguable breach of one or more of the rights under the Convention is in issue, there should be available to the victim a mechanism for establishing any liability of State officials or bodies for that breach. Furthermore, in appropriate cases, compensation for the pecuniary and nonpecuniary damage flowing from the breach should in principle be available as part of the range of redress (see, as a recent authority, T.P. and K.M. v. the United Kingdom [GC], no. 28945/95, §107, ECHR 2001-V). In cases of suspicious deaths, given the fundamental importance of the right to the protection of life, Article 13 requires, in addition to the payment of compensation where appropriate, a thorough and effective investigation capable of leading to the identification and punishment of those responsible for the deprivation of life, including effective access for the complainant to the investigation procedure (see Kaya, cited above, p. 330, § 107; Ergi, cited above, p. 1782, § 98; Salman, cited above, § 123; and Velikova, cited above, § 89). 162. The Court finds that the applicant had an arguable claim under Articles 2 and 3 of the Convention in respect of her son's death and illtreatment and that, for the purposes of Article 13, she should accordingly have been able to avail herself of effective and practical remedies capable of leading to the identification and punishment of those responsible and to an award of compensation. However, in circumstances where – as here and as in Velikova, cited above – the criminal investigation into the suspicious death was ineffective as it lacked sufficient objectivity and thoroughness (see paragraphs 141-46 above), and the effectiveness of any other remedy that may have existed, including the remedy suggested by the Government (the possibility of the

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