March 20, 2011

VI. State Response

Everyone minimizes the extent of racism.… Often the defendant gets attenuating circumstances instead of the aggravating circumstance of racism. We need to work to ensure judges perceive racial aggravation as a threat to our democracy and our society. [225]
— Jean-Léonard Touadi, Italian parliamentarian

Immediately after the Italian government’s review at the UN Human Rights Council, in May 2010, the government accepted a series of recommendations for combating hate violence. Among other things, the government committed itself to strengthen the mandate of the National Office against Racial Discrimination, establish a national human rights institute, and “initiate further concrete measures to stimulate tolerance and prevent discrimination and xenophobia.”[226]  

Yet the Italian authorities continue to minimize the problem and portray migrants and minorities as perpetrators of crime rather than victims of it. This situation has been made worse by the detailed data. As cases above illustrate, the state has failed in many cases to bring to justice those responsible for attacks, and to prosecute crimes against minorities as hate crimes, and to effectively investigate allegations of police abuse.

Downplaying the Problem

There is a striking dissonance between the perception of government representatives of the extent of racism and racist violence in Italy, and that of members of vulnerable groups, along with nongovernmental organizations and international observers. Public authorities tend to minimize the extent of racist violence, calling it episodic and rare. Interior Minister Roberto Maroni said in 2008 “Italy is not today a racist country … some episodes of violence that have occurred recently remain completely marginal and are rejected by society.” [227]   In the wake of the violence in Rosarno, Maroni repeated that “Italy is not a racist country,” explaining that “there are episodes, but the concept of racism is often used for political ends, to attach labels.” [228] In the course of research for this report, several interlocutors, including the director of the National Police Training Institute and the head of a major police officer union, stressed that Italians were not “by nature” racist, and that racist and xenophobic violence is not a statistically significant problem. 

The hate-motivated dimension of events such as the targeted attacks on sub-Saharan African seasonal migrants in Rosarno, the targeting of immigrants for extortion and beatings, and the attacks on Roma settlements, is often minimized or excluded. A representative of the local government of Tor Bella Monaca, the scene of numerous attacks on migrants over the past several years, told Human Rights Watch that these incidents “are not about racism, but rather a problem of cohabitation, of numbers.” [229] He argued that the root of the problem is the neighborhood’s population density and its high proportion of foreigners, saying that one-third of all foreigners in the municipality of Rome live in Tor Bella Monaca. “Today it’s not about racism; if anything, it’s about fear. And it makes sense. Romanians who drink huge quantities from morning to night, or gather in large groups—that’s scary for the elderly woman who finds herself face to face with them.” [230]

Anti-Migrant and Roma Rhetoric

Government officials and politicians from parties in the ruling coalition have engaged in xenophobic and anti-Roma discourse that dehumanizes members of these groups or suggests that being a migrant or a Roma is synonymous with being a criminal.

Boasting of his government’s efforts to fight irregular immigration, Prime Minister Berlusconi said in January 2010 that “a reduction in [the number of] foreigners in Italy means fewer people to swell the ranks of criminals.”[231] At a conference on integration in May 2010, Milan mayor Letizia Moratti, from the People of Liberty party, stated that “illegal immigrants who don’t have regular work usually commit crimes.”[232] 

In an official English-language response to the Council of Europe European Commission against Racism and Intolerance in 2006, the Berlusconi government argued that the “condition of illegality” of irregular immigrants in Italy “is often accompanied by an economic precarious situation, affective deprivation, social exclusion which, together with a widespread condition of inexistent schooling, leads to deviant behaviours; the illegal immigrant is therefore easily involved in criminal activities organized in low-cost unskilled labour.”[233]

Elected officials from the Northern League party in Italy’s coalition government can lay claim to some of the most egregious comments. Party founder and leader Umberto Bossi (who is also minister for reforms in the Berlusconi government) appeared to condone violence against Roma settlements in Ponticelli in May 2008 when he said, “If the state doesn’t do its duty, the people will. After a while people get sick and tired.”[234] Northern League Senator Roberto Calderoli said in a television interview in 2008 that “it is clear that there are some ethnic groups that have a propensity to work and others to commit crimes. This is not due to DNA, rather it is a predisposition.”[235]  

In a hearing at the Italian Senate in September 2008, less than a week after six Africans were gunned down in a gangland shooting in Castelvolturno, a town near Naples, Interior Minister Roberto Maroni characterized the killings as the reaffirmation of territorial control by the local Italian organized crime syndicate against foreign criminals.[236] 

In the same breath, he described the town as having a large presence of primarily African immigrants, linking this to “a situation of marked degradation of the environment, with the diffusion of … drug trafficking, prostitution, and the occupation of entire buildings by illegal immigrants.”[237] The criminal investigation into the episode later demonstrated that the six Africans killed that day were not involved in any criminal activities (see below for more details).

Inadequate Data Collection and Analysis

As noted in Chapter II above, the Italian government does not gather comprehensive national data on racist and xenophobic violence. Systematic collection of data on racist and xenophobic violence, and hate crimes generally, is critical to analyzing trends and ensuring an appropriate response.

The Interior Ministry’s system for classifying hate crimes for statistical purposes uses three broad categories—racism, xenophobia and anti-Semitism—which does not allow for discerning and analyzing trends with respect to particular groups such as Roma, Africans, Muslims, migrants, or asylum-seekers.[238] 

Hate crimes against LGBT people or those with disabilities are not recorded because the Mancino Law does not encompass these categories. Statistics from the Directorate General of Criminal Police for 2004-2009 show there were 27 reports of crimes in violation of Law 205 of 1993 in 2007 and 2008, and 37 such crime reports in 2009.[239] This data is not disaggregated by type of crime, and may include crimes aggravated by racial motivation as well as instigation to racist violence, propaganda of ideas based on racial superiority, and leadership or membership in associations whose objectives include incitement to racism or discrimination.[240] 

Data provided by the Italian government to OSCE’s Office of Democratic Institutions and Human Rights indicated that 142 hate crimes (including “incitement to hatred and insult crimes”) were reported to the police in the first nine months of 2009; of these, 64 were categorized as racist crimes, 31 as xenophobic crimes, and 47 as anti-Semitic crimes.[241] At the time of writing, a Human Rights Watch request to the Directorate General of Criminal Police for disaggregated data was pending.

All police and Carabinieri crime reports are entered into a centralized computer database. The standardized form does not include a specific field for categorizing complaints according to possible racial or other hate motivation; it is at the discretion of the recording officer, who must classify the complaint according to the type of crime, to insert whether the crime may have been racially aggravated.[242]  

Data provided by the Ministry of Justice on “racial discrimination” cases initiated and concluded in 2008 does not allow for detailed analysis. It is not disaggregated by specific crime. Because it is unclear from the data whether the number of pending cases includes cases that were pending from before the beginning of 2008, it is impossible to draw any conclusions about the rate of attrition, i.e. the number of cases that are dismissed. The statistics also do not capture cases in which the prosecutor did not request the application of the aggravating circumstance of racial sentiment. The document does not clarify whether information was obtained from all prosecutor’s offices and trial courts around the country. A representative of the Justice Ministry acknowledged that the collection and systematization of data are partial and problematic. [243]

Data from Public Prosecutor’s Offices 2008 [244]


Suspect(s) Identified

Suspect(s) Not Identified







Transferred to GIP



Alternative procedures requested



Sent to trial






Data from Trial Courts 2008 [245]




Other Rulings [246]

First instance








Juvenile Court




In July 2010 Antonio Manganelli, the national chief of police and head of the public security division of the Interior Ministry, ordered the creation of an Observatory for the Protection of Minority Victims of Discrimination (OSCAD). The office, located within the Central Directorate of Criminal Police, became operational in September 2010 with a mandate to receive directly and to compile and monitor progress on reports of bias crimes.[247]  The creation of the observatory came after significant lobbying by lesbian, gay, bisexual and transgendered (LGBT) organizations following an increase in reported assaults based on the victim’s sexual orientation. According to a representative of the Central Directorate of Criminal Police, OSCAD will address all instances of bias crimes, with a particular focus on and “deeper analysis” for those based on sexual orientation.[248]

Failure to Bring to Justice those Responsible for Attacks

Several cases documented in this report have not led to arrests or prosecutions. In some instances, as in the case of Marco Beyene, assaulted in Naples in March 2009, authorities appear to have investigated diligently. In others, however, it is unclear whether law enforcement and justice officials pursued the cases vigorously. The allegations against Carabinieri for abuse of various members of a Roma family in Bussolengo in September 2008 were never investigated. To our knowledge, no significant progress has been made in identifying those responsible for the mob attack in Tor Bella Monaca on Romanians in November 2007, the mob attack on Romanians in Porta Furba in February 2009, or the attacks on the Roma camp in Ponte Mammolo in September 2007. The fact that the extreme level of violence in Rosarno in January 2010 and in Ponticelli in May 2008 has not been followed up with investigations capable of leading to prosecutions is cause for concern that serious crimes will remain unpunished.

International human rights law establishes a clear duty to provide an effective remedy to victims of violence, whether at the hands of public officials or private individuals. This duty includes the obligation to “exercise due diligence to prevent, punish, investigate, or redress the harm caused by such acts.” [249] The European Court of Human Rights has on multiple occasions reiterated to governments that their obligation with respect to protecting people from harm is not only to refrain from an active infringement by state representatives of the rights in question, but also to take appropriate steps to provide protection against an interference with those rights either by state agents or private individuals.

In light of the seriousness of the incidents cited above, Human Rights Watch is concerned that Italian authorities have not demonstrated sufficient due diligence to investigate and provide appropriate redress.

Failure to Prosecute Attacks as Hate Crimes

The Mancino Law represented a significant innovation in Italian criminal law when it was first adopted in 1993, with the promise of concerted action by the criminal justice system to repress racist and other hate violence. Insufficient implementation of the law and the jurisprudence of national courts have revealed important limitations of the provision creating the aggravating circumstance of hate motivation. Never imported into article 61 of the Criminal Code detailing all aggravating circumstances, the provision is not necessarily widely known or considered.

Lawyers and prosecutors interviewed in the course of this research confirmed that the aggravating circumstance of hate motivation is not particularly well-known by the public or broadly used by the police or prosecutors.[250] There were contrasting views on whether the fact that it is established by special law and not included in the list of general aggravating circumstances in the Italian criminal code played a role. Everyone agreed, however, that a reform to modify article 61 of the criminal code in order to import the aggravating circumstance of hate motivation would be a positive step.[251]

In addition to not being widely known, the Mancino law is also narrowly drawn. As mentioned above, article 3 of the law makes it an aggravating circumstance to commit a crime “with the purpose of discrimination or hatred based on ethnicity, nationality, race, or religion” [emphasis added]. This appears to rule out offenses where the perpetrator has mixed motives.

The widespread view among many legal professionals in Italy interviewed by Human Rights Watch is that violence is racially aggravated within the meaning of the Mancino Law when racial animus is the only determining factor in the commission of the violence, in a situation typically where the perpetrator and the victim do not know each other and have no prior interaction that might give rise to other motivations for the violence. [252]

To make matters even more confusing, the Court of Cassation has conflicting jurisprudence with respect to the interpretation of the aggravating circumstance.

In a June 2008, a section of the Court of Cassation took the view that the aggravating circumstance was applicable in the case under examination because the crime had been “exclusively motivated by consideration of the victim as belonging to a different race.” [253] The case concerned a man who deliberately aimed his car at a person of color at the side of the road yelling to his friends in the car, “I’m going to crush the nigger!” [254]

This jurisprudence was cited in the conviction of two men for the murder of Abdoul Guiebre in Milan in September 2008 to support the prosecutor’s decision to not request the aggravated circumstance. The prosecutor in that case explained to Human Rights Watch that she decided not to request the aggravating circumstance because,

the reaction, certainly disproportionate, of the accused was not determined by racial hatred, but by the theft [they suffered], after the same [the accused] had worked all night.… By law, the aggravating circumstance is applicable to crimes … [committed] “with the purpose of discrimination or ethnic, national, racial, or religious hatred…” In this case, according to what emerged from the investigation, the purpose of the attack was of a different nature.”[255]

The trial judge approved this decision, arguing that the use of racial epithets during the attack “should be read in those circumstances as not different from any other insult.” [256] (The judge noted the perpetrators’ manifest xenophobia, calling this aversion “certainly a motive that inspired the vengeance that was not secondary” to the theft [they] had experienced.) [257]

In July 2010, however, a different section of the Court of Cassation upheld the application of the aggravating circumstance in the case of a violent robbery accompanied by racial epithets. An Italian man was sentenced to four years in prison for a hold-up of an immigrant during which he yelled, “Give me the money, dirty nigger.” In this case, the Court considered that the aggravating circumstance is applicable “when linked, in common understanding, to a manifest prejudice, of the inferiority of a single race.” [258]  

The cases examined by Human Rights Watch suggest that the narrow approach the Court of Cassation in 2008 is the approach commonly taken by the courts in Italy.

The cases of Willy Lulua and Samba Sow demonstrate the effective application of the criminal provision when racist animus appears to be the sole motivation for an assault. But where the alleged perpetrator(s) appear to have other motives, such as in the cases of Abba, Abdul Latif, and the Rosarno violence, the racist dimension of a physical assault may be downplayed by prosecutors and judges or ignored altogether.

The ongoing trial of four alleged members of the Camorra organized crime syndicate for the killing of six African immigrants in Castelvolturno in September 2008 proves a positive exception.  The Naples prosecutor’s office has charged four suspects with racially aggravated homicide for the September 18, 2008 killing spree in which the six men were gunned down in a shower of automatic gunfire. A fifth man collaborated with the justice system and was sentenced separately to 12 years in prison.  

Prosecutors argue that an alleged clan boss, one of the defendants in the case, ordered the killings to send a message to African competitors in the illegal drug market. Cesare Sirignano, one of the prosecutors in the case, explained the logic: “Let’s go kill those blacks, even if innocent, because that way the other blacks, the bad ones, will understand. For them [the defendants] all blacks were the same.… They were supposed to kill blindly even if … the target they were looking for wasn’t there. And that’s what they did.” [259]

In the assessment of Human Rights Watch, the wider interpretation of the law adopted by the Court of Cassation in 2010 is the correct one. As criminologist Tore Bjorgo has argued, offenders usually have mixed motives:

Although the violent acts may have elements of xenophobia or political considerations, such as opposition to current immigration policy, there are typically also distinct nonpolitical motives involved. Frequently, offenders explain that they carried out the violent act in order to show off to their friends, to prove their courage, toughness or loyalty to the group, to avenge prior provocative acts committed by their victims, or just for the thrill of it.[260]

Belgium,[261] the United Kingdom,[262] and the US state of California[263]all provide for mixed motives in their criminal laws outlawing hate offenses that provide positive examples of such an approach.


Failure to Adequately Investigate Allegations of Police Abuse

Four cases discussed in this report involve allegations of police or Carabinieri abuse against Roma. In two of these cases, the victims either filed an official complaint or told justice officials about the abuse. To our knowledge, none of these allegations has been investigated by the competent authorities. In the case involving allegations of abuse by Carabinieri officers in Bussolengo, the competent prosecutor’s office told Human Rights Watch simply that it had conducted no investigation since the complaint had been withdrawn, despite the seriousness of the alleged abuse. In the case involving alleged police abuse of an adult and a minor arrested in a Roma camp, Human Rights Watch was unable to identify the prosecutor and judge who participated in the hearing at which the minor recounted what had occurred.  

Human Rights Watch also spoke with three people who recounted abuse at the hands of the police or Carabinieri, and one witness to violence at the hands of Guardia di Finanza agents. The victims did not file official complaints, and did not want Human Rights Watch to pursue the matter with the relevant authorities. In all of these cases, the precarious situation of the victims—either undocumented migrants or Roma living in makeshift camps—mitigated against reporting the alleged abuse. A South Asian man who claimed a Carabinieri agent grabbed him by the throat and hit his head against a toilet in a Carabinieri station in a southern town explained that, “We’re foreigners here, it’s too dangerous to file a complaint.”[264] 

Furthermore, Human Rights Watch spoke with two individuals who did file complaints after suffering serious injury during operations by municipal police against unlawful peddling of merchandise. In both cases, the prosecutors in charge of the investigations requested the cases be archived; in one case, that request is pending, while in the other, the judge for preliminary investigations rejected the motion and ordered further investigative steps.[265] These two cases, as well as the case concerning the Guardia di Finanza, involved law enforcement officials tripping or kicking visibly foreign street vendors attempting to run away from spot checks.

Failure to diligently investigate, and, where appropriate, prosecute ill-treatment by law enforcement officials not only denies the victims of abuse their right to an effective remedy. It also leads to a lack of accountability and undermines trust in both law enforcement institutions and the justice system. European Court of Human Rights jurisprudence has established the following guiding principles for investigating law enforcement abuse: independence, adequacy, promptness, transparency, and victim involvement.[266] The duty to investigate allegations of ill-treatment is heightened when the victim is in custody at the time. The court has repeatedly asserted that “persons in custody are in a vulnerable position and … the authorities are under a duty to protect them. It is incumbent on the state to account for any injuries suffered in custody.… ”[267]

The absence of an independent body to receive and investigate complaints against law enforcement personnel for misconduct or abuse is an obstacle to accountability and redress for victims. The European Commission against Racism and Intolerance (ECRI), as well as the Council of Europe Commissioner for Human Rights, have stressed the importance of independent mechanisms for filing complaints against law enforcement personnel for racial discrimination or racially motivated misconduct. ECRI argues that such mechanisms should be independent of both the law enforcement agency and the prosecutor’s office because experience has demonstrated that “victims of police abuses do not generally have confidence in the complaints mechanisms internal to the police … [and] are often … reluctant to bring cases before institutions which cooperate closely and on a daily basis with the police, such as prosecution authorities.”[268]

[225] Human Rights Watch interview, Jean-Léonard Touadi, May 28, 2010.

[226] Report of the Working Group on the Universal Periodic Review of Italy, A/HRC/14/4, March 18, 2010, and its Addendum: Views on conclusions and/or recommendations, voluntary commitments and replies by the State under review, A/HRC/14/4/Add.1, May 31, 2010, both available at (accessed July 27, 2010). Italy is one of the few European countries without a national human rights institute. The government submitted draft legislation to create such an institute to the current legislature but it has yet to be examined by parliament.

[227] Interior Minister Roberto Maroni speech in the House of Deputies, October 9, 2008, video available at (accessed February 2, 2011).

[228] “Status di protezione internazionale per alcuni immigrati di Rosarno,”, January 18, 2010, (accessed February 2, 2011).

[229] Human Rights Watch interview with Federico Ceccarelli, spokesperson to the Municipal President and Advisor on General Affairs, Tor Bella Monaca, May 28, 2010.

[230] Ibid.

[231] “Berlusconi accende lo scontro sugli immigrati,” RaiNews24, January 28, 2010, (accessed July 27, 2010).

[232] “La Moratti in Cattolica: ‘Un clandestino di norma delinque.’ È polemica,” Il Corriere della Sera, May 10, 2010, (accessed May 12, 2010).

[233] Italian Remarks on the Draft Third Report of the European Commission against Racism and Intolerance (adopted on 16 December 2005), Rome March 2006, in ECRI’s Third Report on Italy, Adopted on 16 December 2005, p. 48, (accessed December 29, 2010). Emphasis in original.

[234] “Sicurezza, il governo apre alle Badanti. Bossi attaca la Spagna: “voi sparate,” La Stampa, May 18, 2008, (accessed march 19, 2010).

[235] Vari D., “Quattro anni di carcere per il reato di clandestinità, Calderoli etnie criminali,” Liberazione, June 5, 2008.

[236] Maroni testimony to the Senate, September 24, 2008, (accessed October 13, 2010).

[237] Ibid.

[238]ODIHR, Hate Crimes Report of 2007, p. 31; Human Rights Watch interview with a representative of the Central Directorate of Criminal Police, Rome, October 28, 2010.

[239] Delitti commessi, vittime e persone denunciate/arrestate in Italia, Anni 2004-2009, Criminal Analysis Division, Directorate General of Criminal Police. On file with Human Rights Watch.

[240] Articles 1(A) and (B) and 2 of Law no. 205 of 1993 (Legge Mancino).

[241] ODIHR, Hate Crimes in the OSCE Region—Incidents and Responses, Annual Report for 2009, November 2010, (accessed December 9, 2010), see table on p. 25. And text on p. 46 and p. 60.

[242] Human Rights Watch interview with a representative of the Central Directorate of  Criminal Police, Rome, October 28, 2010; Human Rights Watch interview with Felice Romano, secretary general of the Unified Italian Union of Police Employees (SIULP), Rome, July 28, 2010.

[243]Human Rights Watch interview with Gabriele Iuzzolino, Deputy Director, Legislative Office, Justice Ministry, Rome, October 28, 2010.

[244]Ministry of Justice, General Directorate for Statistics, “Dati relative al fenomeno della discriminazione razziale. Anno 2008, Procedimenti penali con autore noto e Procedimenti penali con autore ignoto. Updated statistics as of May 20, 2010. On file with Human Rights Watch. The statistics in the “Suspect(s) Identified” column include both adults and children. Alternative procedures can include plea bargaining, abbreviated trial, immediate trial, and expedited trial for in flagrante charges.


[246] The “other ruling” on appeal may indicate the case was sent back to the lower court for review or retrial.

[247]Human Rights Watch interview with a representive of the Central Directorate of Criminal Police, Rome, October 28, 2010.

[248] Ibid.

[249] Human Rights Committee, General Comment 31, Nature of the General Legal Obligation on States Parties to the Covenant, U.N. Doc. CCPR/C/21/Rev.1/Add.13 (2004), para. 8.

[250] Human Rights Watch interview with Andrea Saccucci, lawyer, president of Unione forense per la tutela dei diritti umani, Rome, March 24, 2010; Human Rights Watch interview with Mario Angelelli and Federica Sorge, lawyers, Rome, March 25, 2010; Human Rights Watch interview with Mario Notargiovanni, lawyer, Rome, March 24, 2010; Human Rights Watch interview with Andrea Mosca, public prosecutor, Rome, July 27, 2010; Human Rights Watch telephone interview with Lorenzo Trucco, lawyer and president of ASGI, Turin, October 7, 2010.

[251] In 2007, a commission set up by the Ministry of Justice to propose reforms to the criminal code recommended including hate motivations—on the grounds of race, religion, nationality, language, political opinion, gender and sexual orientation—in the list of general aggravating circumstances. Commissione Pisapia, Schema di disegno di legge recante delega legislativa al Governo della Repubblica per l’emanazione della parte generale di un nuovo codice penale, June 2007.

[252] Human Rights Watch interview with Mirko Mazzali, lawyer, Milan; Human Rights Watch telephone interview with Rosella Benedetti, lawyer, July 19, 2010. Human Rights Watch interview with Andrea Mosca, public prosecutor, Rome, July 27, 2010; Human Rights Watch telephone interview with Roberta Brera, public prosecutor, July 28, 2010.

[253] Court of Cassation, Section 5, Sentence 38217 of June 12, 2008. Emphasis added.

[254] Ibid. In Italian, the man yelled “Sciaccio il negro!

[255] E-mail correspondence with Roberta Brera, public prosecutor, July 28, 2010.

[256] Tribunale ordinario di Milano, Ufficio per le indagini preliminary, Dott. Nicola Clivio, Sentenza di 16 luglio 2009, proc. n. 33568/08 R.G.N.R., proc n. 7337/08 R.G. G.I.P. On file with Human Rights Watch.

[257] Ibid.

[258] Court of Cassation, Section Two, Sentence 28682 of July 21, 2010. Patrizia Maciocchi, “Condanna più dura se la rapina è a sfondo razzista,” Il Sole 24 Ore, (accessed July 29, 2010). In Italian, the man yelled “Dammi i soldi, sporco negro!”

[259] Conchita Sannino, “Setola uccise degli innocenti,” La Repubblica, September 19, 2010, (accessed October 12, 2010).

[260] Tore Bjørgo, “Violence against ethnic and religious minorities,” in International Handbook of Violence Research, vol. 2, p. 791. Eds. Wilhelm Heitmeyer and John Kagan (Kluwer Academic Publishers: 2003).

[261] Belgian Criminal Code, article 377bis.

[262]Crime and Disorder Act of 1998, section 28; Criminal Justice Act of 2003, section 147.

[263]California Criminal Code, section 422.55.

[264] Human Rights Watch interview with South Asian man, Italy, April 7, 2010.

[265] Human Rights Watch telephone interview with Mario Angelelli, lawyer, Rome, October 15, 2010.

[266]European Court of Human Rights, Taïs v. France, no. 39922/03, judgment of September 1, 2006; Finucane v. United Kingdom, no. 29178/95, judgment of October 1, 2003; Assenov and others v. Bulgaria, no. 90/1997/874/1086, judgment of October 28, 1998; Selmouni v. France, no. 25803/94, judgment of July 28, 1999.

[267]European Court of Human Rights, Keenan v. UK, no. 27229/95, judgment of April 30, 2001, para. 91.

[268] ECRI General Policy Recommendation No. 11 on on Combating Racism and Racial Discrimination in Policing, Explanatory Memorandum, (accessed January 6, 2011), para. 58; Commissioner for Human Rights Thomas Hammarberg, “There must be no impunity for police violence,” December 3, 2007, (accessed January 6, 2011).