provision of services, that approach is difficult to transpose to a case where it is alleged that an act of violence was racially motivated”. Thus, in Zelilof the Court found that it was not established beyond reasonable doubt that racism played a role in the applicant’s ill-treatment by the Greek police. Despite this restrictive construction by the Court concerning substantive violations of Article 3 (and Article 2), in conjunction with Article 14 ECHR, it is to be noted that under the Court’s established case law a state is under a procedural obligation, under the above provisions of ECHR, to investigate possible racist bias in such cases, as was argued by the applicants in Nachova and Others, and was accepted by the Court’s Grand Chamber (§§160-161). Therein the Court underlined the following major points:    When investigating violent incidents and, in particular, deaths at the hands of state agents, state authorities have the duty to take all reasonable steps to unmask any racist motive and to establish whether or not ethnic hatred or prejudice may have played a role in the events. Failing to do so and treating racially induced violence and brutality on an equal footing with cases that have no racist overtones would be to turn a blind eye to the specific nature of acts that are particularly destructive of fundamental rights; A failure to make a distinction in the way in which situations that are essentially different are handled may constitute unjustified treatment irreconcilable with Article 14 ECHR. In order to maintain public confidence in their law enforcement machinery, states must ensure that in the investigation of incidents involving the use of force a distinction is made both in their legal systems and in practice between cases of excessive use of force and of racist killing. The respondent state's obligation to investigate possible racist overtones to a violent act is an obligation to use best endeavours and not absolute. The authorities must do what is reasonable in the circumstances to collect and secure the evidence, explore all practical means of discovering the truth and deliver fully reasoned, impartial and objective decisions, without omitting suspicious facts that may be indicative of a racially induced violence. To date this case law has been applied by the Court also in Greek cases concerning procedural violations of Article 3 and Article 14 ECHR linked to ill-treatment by the police of Roma, but not migrant, applicants.22 Reports on and authorities' action against racist violence by Greek law enforcement agents affecting migrants Although the question of racially motivated migrant ill-treatment in Greek law enforcement has not been tackled to date by the Court, a plethora of data indicate clearly that this is a crucial element to be taken into account in the examination of these cases. In his 2013 report on Greece the Council of Europe Commissioner for Human Rights noted, inter alia, that certain migrants he met and discussed during his visit to Greece informed him of their attempts to contact the police to report racist attacks, which had been met with insults and ill-treatment by the police.23 Of particular concern to the Commissioner were reports indicating that more than half of the police officers who had voted in the special polling stations during the June 2012 parliamentary elections had cast votes for the neo-Nazi political party Golden Dawn well-known for its involvement in, inter alia, very violent attacks and ill-treatment of migrants. The Commissioner was alarmed by this data and called 22 Bekos and Koutropoulos v. Greece, judgment of 13 December 2005; Petropoulou-Tsakiris v. Greece, judgment of 6 December 2007. 23 See the Commissioner’s report, noted above, para. 123. 8