Varanava & Ors v Turkey20, the European Court of Human Rights held: "184. As a logical development of this approach, in the situa�on where persons are found injured or dead, or who have disappeared, in an area within the exclusive control of the authori�es of the State and there is prima facie evidence that the State may be involved, the burden of proof may also shi� to the Government since the events in issue may lie wholly, or in large part, within the exclusive knowledge of the authori�es. If they then fail to disclose crucial documents to enable the Court to establish the facts or otherwise provide a satisfactory and convincing explana�on, strong inferences may be drawn.” 71.4. Bleier v Uruguay 21, the Human Rights Commi�ee of the United Na�ons held: "13.3 With regard to the burden of proof, this cannot rest alone on the author of the communica�on, especially considering that the author and the State party do not always have equal access to the evidence and that frequently the State party alone has access to relevant informa�on ... In cases where the author has submi�ed to the Commi�ee allega�ons supported by substan�al witness tes�mony, as in this case, and where further clarifica�on of the case depends on information exclusively in the hands of the State party, the Commi�ee may consider such allega�ons as substan�ated in the absence of sa�sfactory evidence and explana�ons to the contrary submi�ed by the State party.” 72. Thus, the burden of proof in cases of enforced disappearances rests with the State. This means that the Panel is en�tled to accept inferences submi�ed by Counsel on behalf of the family, Assis�ng Officers of SUHAKAM and Counsel of the Bar Council against the State. It is for the State to adduce sa�sfactory evidence and give explana�ons on a balance of probabili�es to show that the State was not in any way involved in the disappearance of the person within the defini�on of enforced disappearance under Ar�cle 2 of ICPPED. 20 Appl. nos. 16064/90, 16065/90, 16066/90, 16068/90, 16069/90, 16070/90, 16071/90, 16072/90 and 16073/90, Council of Europe: European Court of Human Rights, 18 September 2009 21 Communica�on No. R.7/30, 29 March 1982. 27 PASTOR RAYMOND KOH 71.3.