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The expansion to violations of other rights
So far all cases of ECtHR discussed above concerned death cases under Article 2 ECHR, but the ECtHR expanded the same line of reasoning to include also violations of other rights, for example Articles 3 and 8.
The Bekos and Koutropoulos case concerned mistreatment. At the time of the incident, the two victims, Greek nationals of Roma origin, were 18-years old. They had been arrested by the police while attempting to break into a kiosk. In the course of questioning, they were severely abused. The evidence available to the ECtHR allowed it to conclude that the applicants had been subjected to inhuman and degrading treatment within the meaning of Article 3 ECHR.
In addition, the ECtHR, having regard to the lack of an effective investigation into the credible allegation made by the applicants that they had been ill-treated while in custody, considered that Article 3 had been violated also with regard to its procedural aspect.
In its assessment of Article 14 ECHR, the ECtHR follows closely the line of argument developed in the Nachova case. Aside from statements from international organisations and national human rights groups, the authorities had before them the sworn testimonies of the first applicant that they had been subjected to racial abuse by the police who were responsible for the ill-treatment. Despite this information, the authorities did not examine the question of racist motives of the investigating police officers. The ECtHR concluded that Article 14 ECHR was violated in its procedural aspect.
Another noteworthy case on the requirement to investigate the bias motivation of a crime is the Balázs case. The case concerned his complaint that the authorities had failed to conduct an effective investigation into a racist attack by a penitentiary officer against him. Mr Balázs lodged a criminal complaint against the penitentiary officer, describing the incident and submitting material he had found on the Internet, namely posts by the officer in a social network, according to which the night before he “had kicked in the head a gypsy lying on the ground”. The Public Prosecutor opened a criminal investigation on suspicion of the offence of “violence against a member of a group”. In July 2011 the Prosecutor discontinued the investigation for lack of evidence that the officer had attacked Mr Balázs out of racial hatred. The decision to discontinue the investigation was upheld in September 2011. In May 2012 the officer was convicted of disorderly conduct for becoming involved in a fight and was placed on a one-year probation. Relying on Article 14 (prohibition of discrimination) read in conjunction with Article 3 (prohibition of inhuman or degrading treatment), Mr Balázs complained that the authorities had failed to conduct an effective investigation into the racist attack against him, and in particular that they had not taken sufficient action to establish a possible racist motive for the assault. The ECtHR confirmed a violation of Article 14 read in conjunction with Article 3.
What flows from these initial cases is the obligation, whenever a situation indicates racist motives, for EU Member States to investigate the motivation behind violent offences with a view to unmasking and condemning bias motivation.

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