sufficient guarantees of impartiality and independence in both the institutional and the individual dimension.142 138. In its judgment in the case of Valencia Hinojosa v. Ecuador, the Court pointed out that the police criminal jurisdiction in Ecuador did not form part of the Judiciary, but was functionally and administratively dependent on the Executive. Most of its officials were appointed by the Minister of the Interior at the request of the Commander General of the National Police and, although it was composed of officers most of whom had a legal background, most of them were on active duty in the National Police.143 Also, in that case, the Court concluded: The functional and administrative dependence of the police justice system on the Executive and the impossibility of requesting a judicial review by the ordinary jurisdiction did not guarantee the institutional independence and impartiality of the police jurisdiction. In addition, the relationship of subordination and the chain of command characteristic of the National Police did not offer sufficient guarantees of the personal or individual independence and impartiality of the police criminal judges owing to the way in which they were appointed; the absence of sufficient guarantees of stability in the post (especially in the district courts, where the judges were freely appointed and removed and, as in this case, had competence to determine whether or not a case continued), and the status of officers on active duty of most of those involved (which resulted in the possibility that the district judges, for example, had to investigate higher-ranking officers or their own peers).144 139. Furthermore, in that case, the Court took note of the conclusions of the Ecuadorian Truth Commission which had stressed that the National Court of Justice itself had concluded that the police criminal jurisdiction “did not enjoy autonomy and independence.”145 140. It is also worth emphasizing that, in the judgment handed down by this Court in the case of Grijalva Bueno v. Ecuador, it indicated that “the proceedings that culminated in the imposition of a punishment on Mr. Grijalva Bueno were heard by officials who were functionally dependent on the Executive and, consequently, were not independent judges. However, the Court will not elaborate further on this point owing to the procedural irregularities that invalidated the proceedings and the fact that the State has repealed the laws that established those competences.”146 141. The above criteria were applied in the investigation and prosecution of the presumed victims for the facts referred to in the instant case. Therefore, this Court considers that, from an institutional perspective, the police criminal jurisdiction did not offer guarantees of independence and impartiality in violation of Article 8(1) of the Convention. 142. Moreover, the Court recalls that Article 2 of the Convention obliges States Parties to adopt, in accordance with their constitutional processes and the provisions of this Convention, such legislative or other measures as may be necessary to give effect to the rights or freedoms protected by the Convention.147 The Court takes note of the information provided by the State that, in 2008, Ecuador adopted a new Constitution which abolished the police jurisdiction. However, it underscores that, at 142 Cf. Case of Valencia Hinojosa v. Ecuador, supra, para. 92. Cf. Case of Valencia Hinojosa v. Ecuador, supra, para. 113. It also indicated that: “[i]n this case, by an explicit law, the police criminal jurisdiction depended on the Executive; therefore, from an institutional perspective, it did not offer guarantees of independence and impartiality. Moreover, added to this institutional dependence, the judges, prosecutors and magistrates of the police criminal jurisdiction in Ecuador were appointed and removed by the Minister of the Interior.” Case of Valencia Hinojosa v. Ecuador, supra, para. 97. 143 144 Case of Valencia Hinojosa v. Ecuador, supra, para. 114. 145 Cf. Case of Valencia Hinojosa v. Ecuador, supra, para. 116. 146 Case of Grijalva Bueno v. Ecuador, supra, para. 97. Cf. Case of Gangaram Panday v. Suriname. Preliminary objections. Judgment of December 4, 1991. Series C No. 12, para. 50, and Case of Guachalá Chimbo et al. v. Ecuador. Merits, reparations and costs. Judgment of March 26, 2021. Series No. 423, para. 137. 147 36