110. The Court notes that none of those appearing before it disputed that any claim for damages brought by the applicant and based on alleged ill-treatment by the police would have involved “the determination of his civil rights”. It agrees that Article 6 § 1 is, for that reason, applicable. 111. The Court further notes that the applicant did not deny that both the Law on Obligations and Contracts and the Law on State Responsibility provided him with causes of action which would have enabled him to commence proceedings in the civil courts. He did, however, contend that any such action would have been stayed, perhaps indefinitely, under Article 182(d) of the Code of Civil Procedure. 112. Having regard to the Bulgarian case-law which has been submitted to it by the parties (see paragraph 62 above), the Court notes that the Supreme Court has held, in a case involving a car accident, that a civil court is not bound by the decision of the prosecuting authorities terminating a criminal investigation. The applicant has argued that this rule would not have been applied in his own case, based as it was on allegations of criminal acts much more serious than careless driving. This is, however, a matter of pure speculation, since Mr Assenov did not attempt to bring civil proceedings. In these circumstances, it cannot be said that he was denied access to a court or deprived of a fair hearing in the determination of his civil rights. 113. It follows that there has been no violation of Article 6 § 1 of the Convention. 3. Alleged violation of Article 13 of the Convention 114. The applicant also claimed to have been denied an effective remedy in respect of his Convention complaints, in breach of Article 13, which states: “Everyone whose rights and freedoms as set forth in this Convention are violated shall have an effective remedy before a national authority notwithstanding that the violation has been committed by persons acting in an official capacity.” He submitted that, in cases of alleged ill-treatment contrary to Article 3, the State authorities were under an obligation under Article 13 to investigate promptly and impartially. 115. The Government contended that there had been effective remedies available to the applicant in connection with his allegation of police ill-treatment. This was demonstrated by the fact that, prior to his application to the Commission, he had lodged complaints with the Regional Directorate in Shoumen, the RMPO in Varna and the GMPO in Sofia. Having examined the evidence, the prosecuting authorities had decided that it was insufficient to justify commencing criminal proceedings. In this respect it was to be noted that the applicant had not substantiated his allegations or identified witnesses who would be able to assist in the investigation. 116. The Commission found that the applicant had had an arguable claim to have been illtreated by the police. The official investigation had not been sufficiently thorough and independent to satisfy Article 13.