94 informed consent for such procedures and fully explain the risks, benefits and alternatives in a comprehensible format, without resorting to threats or inducements, in every case[.384] 307. Additionally, the United Nations Interagency Statement established that access should be provided “to administrative and judicial redress mechanisms, remedies and reparations for all people who were subjected to forced, coercive or involuntary sterilization procedures, including compensation for the consequences” and that States should “[p]romptly, independently and impartially investigate all incidents of forced sterilization and ensure appropriate sanctions where responsibility has been established.”385 308. The Inter-American Commission of Women in its Second Hemispheric Report on the Implementation of the Convention of Belém do Pará386 recommended making forced sterilization “a common crime, so that the individual perpetrator can be prosecuted for forcibly sterilizing individual victims.” 309. Meanwhile, the case law of the European Court of Human Rights, which was abundantly cited in the arguments of the parties, has referred mainly to the positive obligations in cases of nonconsensual sterilization, which were examined under the procedural obligation of the prohibition of ill-treatment. The European Court argued that: 123. Articles 1 and 3 of the Convention impose positive obligations on the Contracting Parties, designed to prevent and provide redress for various forms of ill-treatment. In particular, in a similar manner to cases raising an issue under Article 2 of the Convention, there is a requirement to conduct an effective official investigation […]. 124. The investigation in such cases must be thorough and expeditious. However, the failure of any given investigation to produce conclusions does not, by itself, mean that it was ineffective: an obligation to investigate “is not an obligation of result, but of means” […]. 125. In cases raising issues under Article 2 of the Convention in the context of alleged medical malpractice the Court has held that where the infringement of the right to life or to personal integrity is not caused intentionally, the positive obligation imposed by Article 2 to set up an effective judicial system does not necessarily require the provision of a criminal-law remedy in every case. In the specific sphere of medical negligence the obligation may for instance also be satisfied if the legal system affords victims a remedy in the civil courts, either alone or in conjunction with a remedy in the criminal courts, enabling any liability of the doctors concerned to be established and any appropriate civil redress, such as an order for damages and for the publication of the decision, to be obtained […].387 310. Ultimately, a review of international practice reveals that a wide range of measures are considered appropriate to remedy a non-consensual, involuntary, coerced or forced sterilization, depending on the circumstances of the case and the context in which the facts occurred. Nevertheless, the Court considers it necessary to indicate that, if prior, free, full and informed consent is an essential requirement to guarantee that a sterilization is not contrary to international standards, the possibility should also exist to file a claim before the corresponding authorities in those cases in UN, Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, Juan E. Méndez, A/HRC/31/57, January 5, 2016, para. 72.e). 384 Cf. United Nations Interagency Statement “Eliminating forced, coercive and otherwise involuntary sterilization," adopted by OHCHR, UN Women, UNAIDS, UNDP, UNFPA, UNICEF and WHO, 2014 (evidence file, volume VIII, annex 25 to the brief with motions, pleadings and evidence, folio 2459). 385 Cf. OAS, Second Hemispheric Report on the Implementation of the Convention of Belém do Pará, Mechanism to Follow Up on the Implementation of the Inter-American Convention for the Prevention, Punishment and Eradication of Violence against Women (MESECVI), April 2012, p. 43, Available at: https://www.oas.org/es/mesecvi/docs/MESECVISegundoInformeHemisferico-EN.pdf. 386 ECHR, Case of V.C. v. Slovakia, No. 18968/07. Judgment of November 8, 2011, paras. 123 to 125. Similarly, Case of N.B. v. Slovakia, No. 29518/10. Judgment of June 12, 2012, para. 84, and Case of I.G., M.K. and R.H. v. Slovakia, No. 15966/04. Judgment of November 13, 2012, para. 129 (evidence file, volume VIII, annexes 26, 27 and 28 to the brief with motions, pleadings and evidence, folios 2474 to 2577). 387