117. The Court recalls that Article 13 guarantees the availability at 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 this Article is thus to require the provision of a domestic remedy allowing the competent national authority both 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 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. Where an individual has an arguable claim that he has been illtreated in breach of Article 3, the notion of an effective remedy entails, in addition to a thorough and effective investigation of the kind also required by Article 3 (see paragraph 102 above), effective access for the complainant to the investigatory procedure and the payment of compensation where appropriate (see the above-mentioned Aksoy judgment, pp. …, §§ 95 and 98). 118. The Court refers to its above findings that Mr Assenov had an arguable claim that he had been ill-treated by agents of the State and that the domestic investigation of this claim was not sufficiently thorough and effective. It follows from these findings that there has also been a violation of Article 13 of the Convention. ii. Events of and following july 1995 A. Government’s preliminary objections 1. Alleged non-exhaustion of domestic remedies 119. The Government submitted to the Court that the complaints concerning the events of and subsequent to July 1995 should have been declared inadmissible under Article 26 (see paragraph 82 above) since criminal proceedings were still pending against the applicant. Moreover, the applicant had not appealed to the Attorney General against the order refusing his release of 8 December 1995 (see paragraph 40 above). 120. The Commission, in its decision on admissibility, found that the applicant had utilised every remedy available in connection with his complaints under Article 5. 121. The Court notes that Mr Assenov’s complaints under this heading concern various aspects of his detention from July 1995 onwards. It is therefore immaterial that the criminal prosecution against him was still pending at the time of his application to the Commission, since these criminal proceedings would not have provided him with any remedy in respect of the alleged unlawfulness of his preceding detention.