inhuman or degrading treatment) of the European Convention on Human Rights on account of the lack of an effective investigation into the applicants' allegations of ill-treatment". M.C. v Bulgaria In December 2003, the Court ruled in M.C. v Bulgaria that a violation of Articles 3 and 8 of the Convention had occurred. The case discusses the existence of a positive obligation to punish rape and to investigate rape cases. Judge F. Tulkens expressed a concurring opinion in the case. Šečić v Croatia In May 2007 the court reiterated the obligation to secure rights and freedoms. States must take measures to prevent ill-treatment, including ill-treatment administered by private individuals. States must also investigate those ill-treatments. See also Climate change litigation Cruel and unusual punishment United Nations Convention Against Torture European Convention for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment References kar.kent.ac.uk University of Kent, Kent Academic Repository, "Extending the Reach of Human Rights to Encompass Victims of Rape: M.C. v. Bulgaria" Further reading External links A guide to the implementation of Article 3 of the European Convention on Human Rights (PDF) Text of ruling Permanent link to case (using WebCite) 3 European Court of Human Rights cases involving Bulgaria