22 İLHAN v. TURKEY JUDGMENT 18 January 1978, Series A no. 25, pp. 66-67, § 167). In addition to the severity of the treatment, there is a purposive element, as recognised in the United Nations Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, which came into force on 26 June 1987, which defines torture in terms of the intentional infliction of severe pain or suffering with the aim, inter alia, of obtaining information, inflicting punishment or intimidating (Article 1 of the United Nations Convention). 86. The Court has accepted the findings of the Commission concerning the injuries inflicted upon Abdüllatif İlhan, namely, that he was kicked and beaten and struck at least once on the head with a G3 rifle. This resulted in severe bruising and two injuries to the head, which caused brain damage and long-term impairment of function. Notwithstanding the visible injuries to his head and the evident difficulties which Abdüllatif İlhan had in walking and talking, there was a delay of some thirty-six hours in bringing him to a hospital. 87. Having regard to the severity of the ill-treatment suffered by Abdüllatif İlhan and the surrounding circumstances, including the significant lapse in time before he received proper medical attention, the Court finds that he was a victim of very serious and cruel suffering that may be characterised as torture (see also Selmouni v. France [GC], no. 25803/94, §§ 96-105, ECHR 1999-V). 88. The Court concludes that there has been a breach of Article 3 of the Convention in this regard. 2. Concerning the alleged lack of an effective investigation 89. In the Assenov and Others judgment cited above, the Court made a finding of a procedural breach of Article 3 due to the inadequate investigation made by the authorities into the applicant's complaints that he had been severely ill-treated by the police. It had regard, in doing so, to the importance of ensuring that the fundamental prohibition against torture and inhuman and degrading treatment and punishment be effectively secured in the domestic system. 90. However, in that case, the Court had been unable to reach any conclusion as to whether the applicant's injuries had in fact been caused by the police as he alleged. The inability to make any conclusive findings of fact in that regard derived at least in part from the failure of the authorities to react effectively to those complaints at the relevant time (see also Labita v. Italy [GC], no. 26772/95, § 131, ECHR 2000-IV). 91. Procedural obligations have been implied in varying contexts under the Convention, where this has been perceived as necessary to ensure that the rights guaranteed under the Convention are not theoretical or illusory but practical and effective. The obligation to provide an effective investigation into the death caused by, inter alios, the security forces of the