explanation of how the injuries were caused, failing which a clear issue arises under Article 3 of the Convention. It is not sufficient for the State to refer merely to the acquittal of the accused police officers in the course of a criminal prosecution, and consequently, the acquittal of officers on a charge of having assaulted an individual will not discharge the burden of proof on the State under Article 3 of the Convention to show that the injuries suffered by that individual whilst under police control were not caused by the police officers.”35 The Court found that neither the authorities at the domestic level, nor the Government in the proceedings before the Strasbourg Court have advanced any convincing explanation as to the origin of the applicant's injuries. Therefore, the Court considered that the physical harm suffered by the applicant at the hands of the police must have caused the applicant suffering of sufficient severity for the acts of the police to be categorised as inhuman and degrading treatment within the meaning of article 3. Cases Zelilov36 and Galotskin37 concerned the same incident of beating in a police station, but they were tried separately. The involved police officers were acquitted in the disciplinary proceedings, whereas the criminal procedure did not end up in a hearing of the case. The ECtHR held that article 3 had been violated because there had been excessive use of force. Furthermore, it held that the procedural aspect of article 3 had also been violated because the investigations of the incident were sufficiently effective and in particular: the disciplinary investigation was not thorough as required, it evaluated selectively and inconsistently the evidence, it did not take into consideration the forensic report, the criminal investigation was not initiated ex officio and it was basically based on the disciplinary investigation without examining as witness the complainant. With the same reasoning the ECtHR held in Galotskin case that both substantive and procedural aspect of article 3 had been violated.38 The Stefanou case concerned the beating of an under-age Roma in a police station. The ECtHR considered that the Government had not established beyond Ibid., par. 27. Zelilof v. Greece, Judgment of 24 May 2007. 37 Galotskin v. Greece, Judgment of 14 January 2010. 38 Pending cases regarding police ill-treatment: Zontul v. Greece, (Application No. 12294/07), A.A. v. Greece, (Application No. 12186/08). 35 36 12