ERGI JUDGMENT OF 28 JULY 1998 29 where State officials had been tried in criminal courts, the administrative courts were empowered to award compensation for damages, irrespective of whether the official concerned had been convicted or acquitted. Some of these judgments had concerned cases brought by the families of police officers and teachers killed by the PKK where it had not been possible to identify the authors and where the administrative courts had nevertheless made awards for damages to the families. In a number of cases, victims of bomb attacks had obtained damages from the administrative courts. Many of these judgments had concerned loss of life in circumstances comparable to those in the case under consideration. All of these rulings had been in the claimants’ favour. 93. The Commission recalled its finding that the absence of any adequate and effective investigation into the killing of Havva Ergi constituted a breach of Article 2 of the Convention (see paragraph 70 above). Since this matter also underlay the applicant’s complaints under Article 13 of the Convention, it found it unnecessary to examine them separately. 94. The applicant, disputing the Commission’s conclusion, maintained that the duty of a State under Article 2 to carry out an effective investigation into an unlawful killing was not conterminous with the right to an effective remedy under Article 13. While under Article 2 the effectiveness of the investigation was considered in the context of the right to life, under Article 13 it was considered in connection with the right to an effective remedy. The scope of the Article 2 obligation was limited to what had occurred whereas that under Article 13 required not only an effective investigation but also that the system of securing the remedy be effective. 95. As to the case-law referred to by the Government, the applicant pointed out that only four of the new administrative court decisions, namely Yıldırım, Uçoş, Demirkıran and Curabaz, raised an issue even remotely similar to the present case, since only those four concerned complaints about actions involving the security forces. In those cases, although the claimants had been awarded compensation, the events in issue were never the subject of any criminal investigation. 96. The Court recalls that Article 13 of the Convention guarantees the availability at the 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 the relevant Convention complaint 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, in