on the authorities to be vigilant, to sanction and remove from their posts law enforcement officers who are motivated by racism. Equally alarming has been the continuous recording by the Racist Violence Recording Network (RVRN)24 since 2012 of numerous incidents concerning hate crime, including racist attacks, in Greece, involving law enforcement officials: In 2012 RVRN recorded25 25 incidents where police and racist violence were interlinked. In seven of them migrants were allegedly ill-treated while in police detention; in 17 of these reported incidents law enforcement officials were involved in racist attacks while carrying out routine controls; in another case a law enforcement official allegedly cooperated with members of extremist groups in an assault against a migrants’ house. The following year RVRN recorded26 31 racist crime incidents where law enforcement officials were involved. In its 2013 annual report RVRN underlined the urgent need for Greece to deal effectively with reports indicating unlawful practice by law enforcement officers, including acts which appear to be racially or otherwise biased. The two major recommendations made by RVRN in this context were: first, that state authorities unconditionally condemn all acts of police brutality and arbitrariness; secondly, the need to establish an effective police complaint mechanism. Both recommendations were shared by the Council of Europe Commissioner for Human Rights in his aforementioned 2013 report on Greece as well as in a relevant letter he sent to the Ministries of Interior and of Justice in 2016.27 In 2014 RVRN recorded 17 racist violence incidents involving law enforcement officials.28 In these cases law enforcement officials were reportedly involved in inflicting notably bodily harm and in verbal abuse of the victims on the ground of the latter’s ethnic origin, skin colour or religion. In 2015 RVRN received 11 complaints concerning unlawful violence involving law enforcement agents against refugees and immigrants.29 In most of these cases law enforcement officials were reported having being involved in arbitrary acts and violence against the non-nationals during the exercise of their duties. Characteristically, only in two out of the 11 cases the victims wished to report the incidents. The existence of cases of racially biased ill-treatment of migrants, among others, by police officers has not really been denied by the leadership of the Greek police. On 24 May 2006 the Head of the Greek police issued a circular30 that appears to be a consequence of the 2005 judgment by the Strasbourg Court in the above-mentioned case of Bekos and Koutropoulos v. Greece, concerning police ill-treatment of the Greek Roma applicants and lack of an effective investigation, including the non-examination of the impugned policemen’s racial bias. After making reference to the above judgment the Head of the Greek Police noted that the duty of examining the possible existence of racial motivation, ethnic hatred or intolerance concerns all cases, including those emanating from 24 RVRN is a network of Greek NGOs that was established in 2011 by UNHCR and the Greek National Commission for Human Rights; more information is available at: www.rvrn.org. 25 RVRN 2012 Annual Report, 16 April 2013, available at: http://rvrn.org/2013/04/2012-annual-report/. 26 RVRN 2013 Annual report, 2 April 2014, available at: http://rvrn.org/wpcontent/uploads/2014/04/Report2013_EN.pdf. 27 See Commissioner’s letter to Alternate Minister of Interior Toskas and to Minister of Justice Paraskevopoulos, 25 July 2016, available at: https://wcd.coe.int/ViewDoc.jsp?p=&Ref=CommDH(2016)29&Language=lanEnglish&direct=true. 28 RVRN 2014 Annual Report, 6 May 2015, available at: http://rvrn.org/wpcontent/uploads/2015/05/Report_2014eng.pdf. 29 RVRN 2015 Annual Report, 19 April 2016, available at: http://rvrn.org/wpcontent/uploads/2016/04/Report_2015eng.pdf. 30Circular 7100/4/3, “The handling of racism, xenophobia, and intolerance during police action”, 24 May 2006, on file with the author. 9