ABSTRACT

In 2009, the Council of Europe published the Opinion of the Commissioner for Human Rights Concerning Independent and Eective Determination of Complaints against the Police (Commissioner for Human Rights, 2009a; Smith, 2010). e Opinion set out ve eective investigation principles developed in the case law of the European Convention on Human Rights (ECHR) and recommended that compliance with human rights standards could most eectively be achieved by creation of an independent police complaints body (IPCB).