internationally wrongful act depends first, on the requirements of obligation which is said to have been breached, and secondly, whether the state party or the organs or agents or officials committed the breach which the state party should be held responsible of the action.” In line with the above, it is well-established that the conduct of any organ of a state is regarded as act of that state. The Plaintiff contends that the Defendant did not conduct an effective investigation as the investigation report annexed to the Defendant defence reveals that the statement of the two police officers involved in the incident were taken at exactly the same time. A report can only be considered detailed and impartial if parties involved are interviewed separately. Where both parties involved in the incident are interviewed at the same time, the whole essence of the investigation is defeated as there would be a corroboration in the narrations. There are no general rules as to what constitutes an effective investigation. In a case of an alleged ill-treatment as in the present case, it is the responsibility of a State to take necessary steps to conduct an effective official investigation. This investigation must be carried out impartially and promptly and must consist of a comprehensive report of all the submissions of the parties involved in the case which must be deduced separately, the conduct/manner, the place and time the investigation was carried out. 22

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