ANGUELOVA v. BULGARIA JUDGMENT 21 Government had developed their own arbitrary theory for the purposes of the present case. In reality, it was obvious that the injuries were the result of ill-treatment and that, in the absence of any evidence to the contrary, they must have been inflicted at the same time as the fatal skull injury. 105. The applicant also considered it particularly striking that no explanation had been provided concerning the suspect behaviour of the police officers and their conspicuous attempt to forge the detention register. (b) The Government 106. The Government, referring to the second forensic report, stated that the fatal injury had been inflicted more than ten hours prior to Mr Zabchekov's death and, therefore, long before his arrest. It was undisputed that Mr Zabchekov had consumed a large quantity of alcohol before his arrest. He had been drunk and staggering. Furthermore, there was clear evidence that he had fallen several times while running. In the Government's view the evidence concerning his behaviour at the time of his arrest and detention – which corresponded to the typical symptoms of a “lucid interval” after a skull fracture – confirmed the medical experts' conclusions about the timing of the fatal injury. 107. The Government pointed out that the statements of the witnesses relating to the whereabouts of Mr Zabchekov prior to his arrest contained contradictions. Furthermore, on several occasions in 1995 the applicant had stated that her son was ill and – when younger – had sometimes lost consciousness and suffocated. Mr Zabchekov himself had confirmed in 1995 that he had suffered from headaches and fainting. On that basis, the Government concluded that the experts' finding that Mr Zabchekov might have received the fatal injury by falling on a broad hard surface was plausible. 108. The Government stressed that there was no evidence of any illtreatment by the police. In their view, the injuries to Mr Zabchekov's chest and face must have been the result of his falling on the ground, and those to his wrists must have been caused by the normal use of handcuffs. 2. The Court's assessment (a) General principles 109. Article 2 of the Convention, which safeguards the right to life, ranks as one of the most fundamental provisions in the Convention. Together with Article 3, it enshrines one of the basic values of the democratic societies making up the Council of Europe. The object and purpose of the Convention as an instrument for the protection of individual human beings also requires that Article 2 be interpreted and applied so as to make its safeguards practical and effective (see McCann and Others v. the

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