P.M. v. BULGARIA JUDGMENT 7 A. Admissibility 1. Competence ratione temporis 55. Although the respondent Government have not raised any objection as to the Court’s competence ratione temporis, this issue nevertheless calls for consideration by the Court (see Blečić v. Croatia [GC], no. 59532/00, §§ 63 et seq., ECHR 2006-III). 56. The Court has stated that the procedural obligation to carry out an effective and prompt investigation under Article 2 has evolved into a separate and autonomous duty capable of binding the State, even when the substantive act took place before the critical date (see Šilih v. Slovenia [GC], no. 71463/01, § 159, 9 April 2009). For such a procedural obligation to come into effect, a significant proportion of the investigating steps required by this provision will have been or ought to have been taken after the critical date (ibid., § 163). Subsequently the Court applied this principle to cases concerning deaths at the hands of private individuals (see Lyubov Efimenko v. Ukraine, no. 75726/01, § 63, 25 November 2010; and Frandeş v. Romania (dec.) no. 35802/05, 17 May 2011). Furthermore, in Tuna v. Turkey (no. 22339/03, § 58, 19 January 2010) and in Stanimirović v. Serbia (no. 26088/06, § 28, 18 October 2011, not yet final), it went on to hold that the principles established in Šilih applied similarly to the procedural obligation to investigate under Article 3. 57. In the present case, while the sexual offences against the applicant were committed in 1991, before the entry into force of the Convention in respect of Bulgaria on 7 September 1992, most of the procedural steps were taken after that date (see paragraphs 9-51 above). 58. In view of the above, the Court finds that the alleged procedural violation of Article 3 falls within the Court’s temporal jurisdiction and that it is therefore competent to examine this part of the application. It is true that the applicant also relied on Article 8 in the present case and that in the case of M.C. v. Bulgaria (no. 39272/98, ECHR 2003-XII) the Court referred to both Article 3 and Article 8, finding that there was an obligation on States to enact criminal-law provisions effectively punishing rape and to apply them in practice through effective investigation (see §§ 148-153 of that judgment). Noting that in the present case the applicant’s complaints are limited to the effectiveness of the investigation and that Article 3 provides sufficient legal basis for the State’s duty to conduct an investigation into serious offences against an individual’s physical integrity, the Court considers that it is not necessary in the particular circumstances of the instant case to decide whether its temporal jurisdiction also extends, in situations like the present one, to issues under Article 8. Therefore it will confine itself to determining whether the events that occurred after the entry