reasonable doubt that the bruises on the applicant’s head pre-dated his questioning at the police station, and found a violation of article 3.39 C) The Greek Ombudsman The Greek Ombudsman issued in 2004 a special report titled “DisciplinaryAdministrative Investigation of Complaints against Police Officers”. Out of 176 complaints received by the Greek Ombudsman concerning the behavior of police officers, 26 concerned brutality and/or ill-treatment. The outcomes of the Greek Ombudsman’s survey in relation to all filed complaints were the following: a) crucial factors for the reliability of the conducted investigations are the strict implementation of the disciplinary procedure and the sufficiently reasoned decision in writing, b) whereas the legal framework aims at providing the investigation of the most serious offences with increased guarantees, in practice there is extensive use of the informal procedure, c) there is lack of initiating Sworn Administrative Inquiries in cases where there were evidence to justify disciplinary proceedings, even in cases where the alleged treatment would fall under article 3 of the ECHR, d) in cases where the investigation was conducted by the Commanding Officer of the involved police station there were indications of less scrutinized investigation that the one required on the basis of the available evidence. For that reason the assignment of the investigation to an Officer of another Directorate should be expanded in all internal police investigations. e) the Greek Police could enhance the transparency and reliability of its internal investigations by consistently suspending the officer against whom a Sworn Administrative Inquiry has been initiated for a serious disciplinary offence. f) a number of violations of the principle of full and reasoned evaluation of evidence has been substantiated. g) there are serious and fundamental violations of the rules regarding the evidentiary procedure, h) there are shortcomings with regard to substantive and efficient reasoning of decisions, i) there is an abusive expansive interpretation of the provisions regarding the discretionary powers for conducting a disciplinary 39 Stefanou v. Greece, Judgment of 22 April 2010, par. 49-52. 13