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In view of the above, the Court is satisfied that the applicant has submitted sufficient elements to create a strong presumption that he had sustained the severe bodily injuries complained of during his incarceration, and to shift the burden of proof to the Government (compare Bouyid, cited above, § 83; contrast Perkov v. Croatia, no. 33754/16, § 48, 20 September 2022).

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In particular, when there is reason to believe that an individual has been subjected to ill-treatment by a State official, the State is required to conduct an effective official investigation (ibid., § 116; and Tadic v. Croatia, no. 10633/15, § 41, 23 November 2017).

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Admissibility 11. As regards the Government's contention that the applicant had failed to exhaust domestic remedies by not having lodged a constitutional complaint, the Court notes that it has already rejected a similar preliminary objection in the context of both a procedural and a substantive complaint under Article 2 of the Convention in the case of Daraibou v. Croatia (no. 84523/17, §§ 66-70, 17 January 2023).

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It sees no reason to depart from those conclusions in the present case, where the competent State Attorney's Office dismissed the applicant's criminal complaint in January 2018 (see paragraph 9 above), whereas a constitutional complaint became an effective domestic remedy for complaints concerning ineffective investigations under Articles 2 and 3 of the Convention in 2019 (see Ku?.ic and Others v. Croatia (dec.), no. 71667/17, § 99, 10 December 2019).