Deportation torture essay

Student ID: 200771848 International Human Rights 2142 word count: 3,287

Introduction

It is commonly understood amongst the international

community that freedom from torture is an inalienable

right, inherent in every human being. However, with the

contemporary challenges that states’ face, the freedom

from torture in the non-refoulement context presents

problems and thus the question is asked, can deportation

to face torture be justified in exceptional

circumstances?

The following will start by discussing the international

human rights legal framework with a focus on the level of

protection it provides whilst discussing the legal

loopholes states may use to justify deportation. In

addition, discussion will be given to the ‘absolute

approach’ that has been taken by judicial and

international bodies.

This essay will then move on to analyse international

refugee law and how such law has presented significant

contradictions, which governments have used as a

foundation to justify deportation to face torture.

Once establishing the legal framework that surrounds this

area, this essay will then move on to discuss various

positions for and against the justification of torture in

a moral and philosophical context. Finally, discussion

Student ID: 200771848 International Human Rights 2142 word count: 3,287will be given to use of diplomatic assurances as a method

of circumventing the absolute nature of non-refoulement,

which derives from the prohibition of torture.

Protection and Room for Justification within the Legal

Framework

When considering international human rights law the

United Nations Convention against Torture (UNCAT)1

provides a logical starting point. Article one of the

convention defines the term torture for the purposes of

the document.

Within article one there is a lawful sanctions clause. It

states that the definition of torture for the purposes of

the convention “does not include pain or suffering

arising from inherent in or incidental to lawful

sanctions”2. This clause has been the subject of

controversial debate. Manfred Nowak has referred to how

the clause has been used by Islamic and other states to

justify severe cases of corporal and capital punishment3.

Nowak expands on this statement by discussing the

examination of the 2002 report of Saudi Arabia by the

1 United Nations Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment 1984 (hereinafter known as the Convention against Torture) 2 above, No1, Art 13 M. Nowak, ‘Challenges to the absolute nature of the Prohibition of Torture and ill-treatment’, Netherlands Quarterly of Human Rights, 23 (2005), 680

Student ID: 200771848 International Human Rights 2142 word count: 3,287Committee Against Torture (CAT)4. Within the report it was

stated by Saudi Arabia that the Koran set out whipping,

amputation and stoning for certain crimes, that it was

the law of the land and therefore permitted by the lawful

sanctions clause.

Nowak concludes that systematic interpretations of

article one’s lawful sanctions clause remain unclear and

thus the clause has no scope of application and must be

ignored5. The question is how does this relate to the

refoulement of persons? It may be said that, the lawful

sanctions clause enables states such as Saudi Arabia to

justify, what some would consider, acts of torture. Thus,

states wishing to deport persons to such countries may

justify such deportation on the grounds that the

individual is, in fact, not going to face torture, or at

least, not face torture under the definition of UNCAT.

Article 3 of UNCAT states that no state shall return or

extradite a person to another state where there are

substantial grounds for believing that he would be in

danger of being subject to torture6. It would appear that

article three has a significant lacuna as it fails to

encompass cruel inhuman and degrading treatment (CIDT).

4 UN Docs CAT/C/SR.519 and 5255 M. Nowak, above No 2, 6836 Convention against Torture, Art 3

Student ID: 200771848 International Human Rights 2142 word count: 3,287Such a position presents problems since the definitive

line between CIDT and torture is somewhat grey. This was

recognised by the Committee against Torture (CAT) in

their general comment two of 2007, which stated that it

is difficult to ascertain the threshold between ill-

treatment and torture7. However, following the failure of

CAT to elaborate on the non-derogability of CIDT within

the principle of non-refoulement8, states may be able to

justify deportation to face CIDT, when in fact the

individual is likely to face torture. It may be said that

this position undermines the absolute nature of the

prohibition against torture.

In addition the protection that UNCAT offers is limited

to those acts that are carried out by or acquiesced by

state officials9, thus any threat of torture that may

emanate from a non-state party is an immaterial

consideration under the convention. This prevents a

significant lack of protection to those that are deported

on grounds of national security. A recent example of a

deportation to, more likely than not, face torture is the

United Kingdom’s deportation of a Pakistani activist who

has received threats from the Taliban10. The deportation 7 General Comment 2, CAT/C/GC/2/CRP.1/Rev.4, 23 Nov, 2007,para 3 8 Aoife Duffy. ‘Expulsion to Face Torture? Non-refoulementin International Law’, p3809 Convention against Torture 1984, A1, A1610 https://newhumanist.org.uk/articles/4764/uk-to-deport-pakistani-activist-who-has-received-taliban-death-threats> accessed 1st January 15

Student ID: 200771848 International Human Rights 2142 word count: 3,287is almost certain to result in torture, however the UK is

able to legally justify the deportation, as the threats

emanate from a non-state actor.

The International Covenant on Civil and Political Rights11

(ICCPR) provides individuals who face refoulement a wider

avenue of protection as article seven provides for both

torture and CIDT12. The covenant does not expressly extend

the right to the principle of non-refoulement. However,

within general comment twenty of the Human Rights

Committee acknowledges the principle of non-refoulement

and rejects the possibility of states deporting persons

to face torture or CIDT13. Moreover in March 2004, the

Human Rights Committee adopted general comment thirty one

which stated that no state shall deport a person to one

state where there is a risk of subsequently being

deported to a another state where there is a risk of

being subject to violations of article seven14.

We can see that with the ICCPR also encompassing CIDT

into the ‘absolute prohibition’ stance that it takes

against refoulement, that it offers individuals a wider

scope of protection when addressing the issue of non-

refoulement.

11 International Covenant on Civil and Political Rights 1966 (hereinafter known as ICCPR)12 ICCPR, Article 713 GC20, HRI/GEN/1/Rev.1 (1994), 30, s.9 14 CCPR/C/21/Rev.1/Add.13, para 12

Student ID: 200771848 International Human Rights 2142 word count: 3,287Although not universally applicable the European

Convention of Human Rights15 provides a clear

demonstration of the European stance on the prohibition

on torture. Article three of the convention provides that

no one shall be subjected to torture or CIDT16. In the

case of Ireland v UK the European Court of Human Rights

affirmed the absolute nature of the article three rights

irrespective of the individuals conduct17. Moreover, in

the case of Soering the European Court of Human Rights

extended the article three rights to cases of non-

refoulement by holding that the deportation of a man to

the USA to face the death penalty was contrary to the

spirit of the article18. Finally in the case of Chahal the

court reaffirm the absolute nature of the article three

rights and affirmed their absolute position in the

context of non-refoulement even in times of national

emergency19.

Aoife Duffy has suggested that, although not universally

applicable the ECHR offers a greater level of protection

than the UNCAT as it holds both torture and CIDT as non-

derogable within non-refoulement20.

15 European Convention for the Protection of Human Rights and Fundamental Freedoms (hereinafter known as the ECHR),Rome, 4 Nov, 195016 The ECHR, above, No15, Art 3 17 Ireland v United Kingdom (1978) ECHR, Series A, No 2518 Soering v UK (1989) ECHR, Series A, No161, para 8819 Chahal v United Kingdom (1996) ECHR, para 8020 A. Duffy, above, No 7, 379

Student ID: 200771848 International Human Rights 2142 word count: 3,287When discussing international instruments applicable to

refoulement it is also necessary to discuss the

Convention Relating to the Status of Refugees21. Article

33(1)22 incorporates the rule of non-refoulement. However,

33(2) states that the above may not apply to those who

pose a threat to the security of the country that he is

in23. However, article 33(2) is not the only exception,

article 1(f) allows states to refuse admission24.

Moreover, article 1(f)(c) refers to the exclusion of

persons who have committed acts that run contrary to

purposes and principle of the United Nations25. Both of

these exclusions clearly run contrary to the absolute

position that we have seen in the above instruments. They

provide for a balancing between national security and the

rights of the individual, thus enabling states to justify

the deportation of persons to face torture.

Justifying Torture

As we have seen above, UNCAT, ICCPR and the European

Convention provide an absolute, non-derogable approach on

the prohibition on torture. Thus it may be concluded,

that under international obligations there are no

exceptional circumstances that justify the deportation of

21 The Convention Relating to the Status of Refugees (hereinafter known as the Refugee Convention) (1954) 22 Refugee Convention, Art 33(1)23 ibid, Art 33(2)24 ibid, Art 1(f)25 ibid, Art 1(f)(c)

Student ID: 200771848 International Human Rights 2142 word count: 3,287an individual to face torture. However, it has been

suggested that with the modern terror threats states are

faced with, it is hard to conclude that the principle of

non-refoulement has acquired peremptory status26.

Domestic case law has opened the door to the idea of

possible exceptions, similar to those that we have seen

in the Refugee Convention. The case of Suresh v Canada27

concerned the deportation of a former Tamil Tiger

(terrorist group in Sri Lanka), Suresh claimed that if

deported he would face torture. However, the focus of the

Supreme Court judgement seemed to be on domestic

legislation rather than Canada’s international

obligation. The court stated, “International norms are

not necessarily binding, unless incorporated into

Canadian law”28. The court further stated, “We do not

exclude the possibility that in exceptional

circumstances, deportation to face torture might be

justified”29. This clearly displays an attitude that the

absolute prohibition on torture is not absolute, but in

fact may be balanced against matters of national

security. It may be said that such an approach undermines

the rights that international instruments seek to

protect.

26 Aoife Duffy article, above, No 7, 38227 Suresh v Canada (Minister of Citizenship and Immigration), Supreme Court of Canada [2002] SCC 1 28 ibid, para 6029 ibid, para 78

Student ID: 200771848 International Human Rights 2142 word count: 3,287The Human Rights Committee condemned the decision in

their concluding observations30. They stated that article

seven31 was non-derogable and that Canada should

acknowledge this and incorporate it into their legal

system32.

The Suresh case presented a challenge to the non-

derogability of the principle of non-refoulement and

demonstrated a reaction to the extreme circumstances that

contemporary governments face.

Both the Human Rights Committee and the Committee Against

Torture have subsequently reaffirmed the absolute nature

of the prohibition against torture in the cases of Alzery

v Sweden33 and Agiza v Sweden34, where both bodies held the

deportation of Egyptian nationals on countervailing

considerations of national security to be violations of

article three (UNCAT) and article seven (ICCPR).

Despite the reaffirmation of the absolute position of

non-refoulement governments continue to challenge it. The30 Concluding Observations of the Human Rights Committee, Canada, U.N. Doc. CCPR/C/CAN/CO/5 (2006)

31 ICCPR 1966, Article 7 (freedom from torture and CIDT)32 Concluding Observations of the Human Rights Committee, Canada, U.N. Doc. CCPR/C/CAN/CO/5 (2006), para 15

33 Alzery v Sweden, Human Rights Committee, UN Doc CCPR/C/88/D/1416/200534 Agiza v Sweden, Committee against Torture, UN Doc CAT/C/34/D/233/2003

Student ID: 200771848 International Human Rights 2142 word count: 3,287case of Ramzy v Netherlands35 provides a good example of

modern governments seeking the reform the absolute

approach. The case concerned the deportation of an

Algerian national who claimed that if deported would be

exposed to a real risk of torture and thus a violation of

article three under the ECHR. The UK alongside Portugal,

Lithuania, Slovakia and the Netherlands sought to reform

the absolute principle that was established in the

earlier case of Chahal36 (discussed above).

The thrust of the argument put forward by the intervening

governments was that the Chahal decision was too

restrictive and reform should allow states to balance the

risk of harm against national security considerations37.

In addition to the UK’s intervention in the Ramzy case,

the UK also intervened in the case of Saadi v Italy38 in

another attempt to revisit the Chahal decision. The UK

argued that the decision in Chahal prevented contracting

states from weighing the right against matters of

national security39, further, that the approach did not 35 Ramzy v Netherlands, European Court of Human Rights, Application No. 25424/05 (2008) 36 Chahal v UK, above, No 1937 Alexander Horne, Melanie Gower & Joanna Dawson, ‘Deportation of Individuals who may Face Torture’ House of Commons publication, 2014, p30

38 Saadi v Italy, European Court of Human Rights, Application No. 37201/06, judgment of February 200839 ibid, para 117

Student ID: 200771848 International Human Rights 2142 word count: 3,287reflect the universally recognised imperative and

contradicted the initial intentions of the signatories40.

Moreover, the UK argued that within cases concerning

national security the burden of proof on the applicant

should be greater, suggesting that it should be

demonstrated to be ‘more likely than not’ that torture

will occur upon deportation41.

The European Court of Human Rights rejected the UK’s

arguments. They stated that there could be no derogation

from the absolute principle of article three and that the

weighing up of risk of torture and the dangerousness of

the person is an idea that is misconceived42. We can see

that through domestic case law and the challenges within

Europe to the absolute nature of non-refoulement that

states have sought to justify the deportation of persons

on the grounds of national security. It may be argued

that adopting a stance that balances freedom from torture

and national security is merely creating a tool that

takes into consideration the right to life of those who

reside in the concerned state. Does the freedom from

torture of one person justify risking the life of many?

It is such an argument that both governments and

academics have sought when justifying the use of torture,

an argument that is applicable when discussing challenges

to the absolute nature of non-refoulement.

40 ibid, para 12241 ibid42 ibid, para 138

Student ID: 200771848 International Human Rights 2142 word count: 3,287

Alan Dershowitz has suggested the idea of legalising

torture is certain circumstances through a torture

warrant obtained through a judicial body43. Dershowitz

uses the idea of a torture warrant within the ticking

time bomb scenario making reference to how, if confronted

with this situation most authorities would resort to the

use of torture. Dershowitz also raises the argument that

considering the level of inevitability of torture within

such a scenario the use of torture warrants would create

accountability which is consistent with our democratic

values. Moreover, Dershowitz refers to this argument in

an article in the LA Times44. Within the article

Dershowitz makes reference to how democracy requires

accountability and transparency and importantly

compliance with the rule of law. And that such compliance

is impossible when an extraordinary technique, such as

torture, operates outside of the law.

It may be said that such an argument is relevant when

addressing the issue of non-refoulement. If states were

able to deport person through the balancing of rights

against countervailing considerations, a degree of

accountability and transparency would be created on the

international plane. Dershowitz refers to how authorities43 http://www.alandershowitz.com/publications/docs/torturewarrants2.html> accessed 2 January 1544 http://articles.latimes.com/2001/nov/08/local/me-1494> accessed 2 January 15

Student ID: 200771848 International Human Rights 2142 word count: 3,287would inevitably use torture within a ticking time bomb

scenario. Can the same not be said for governments

wishing to deport persons in order to protect their

national security interests? One might say that a state

protecting its interests is inevitable. We can see this

in the case of Othman45(discussed later in the essay) when

the UK deported an individual to Jordan despite the

European Courts dissent. Thus it may be said, that the

absolute approach to refoulement currently adopted does

not provide for this.

However, Dershowitz’s argument has not gone without

criticism. William Schulz heavily criticised the idea of

a torture warrant in his article ‘the torturer’s

apprentice’46. Schulz states that apart from Dershowitz’s

argument condoning the inherently abhorrent act of

torture, there are pragmatic reasons for dismissing it.

Schulz refers to how the time bomb scenario makes the

assumption that the authorities have all the required

information i.e. they know that there is definitely a

bomb that will go off, that the suspect knows it is going

to go off and that he or she has the relevant information

to stop it. This is certainly an argument that may rebut

any argument that promotes the balancing or rights

45 Othman (Abu Qatada) v. United Kingdom (Appl. No. 8139/09), Judgment of 17 January 2012, European Court of Human Rights (4th sect.)46 William F Schulz, ‘The Torturer’s Apprentice’, The Nation, 2002

Student ID: 200771848 International Human Rights 2142 word count: 3,287against national security within the context of

refoulement.

It cannot definitively said that the person a state

wishes to deport does present a threat to national

security to a level that would inevitably endanger lives

and thus justify his or her deportation to face torture.

Circumventing International Obligations

Thus far we have seen a change in the attitude of

signatory states as to the absolute nature of non-

refoulement and further academic attempts to justify the

use of torture. With the absolute nature of non-

refoulement states, when deporting individuals to

countries with questionable human rights records have

sought to rely on diplomatic assurances.

Diplomatic assurances provide deporting state with the

assurance that the deported individual will be free from

any violations of international obligations47. Sweden in

the cases of Agiza48 and Alzery49 relied on diplomatic

assurances when deporting two individuals to Egypt. The

UK has also sought to rely on diplomatic assurances. The

UK has established memoranda of understanding (MOU) with

47 Article 3 of UNCAT, Article 3 of the ECHR, Article 7 ofICCPR and even article 33 (1) of the Refugee Convention48 Above, No 3449 Above, No 33

Student ID: 200771848 International Human Rights 2142 word count: 3,287Jordan, Algeria, Libya and Lebanon50 to facilitate

deportations.

The above assurances were given credit by the then

foreign secretary Jack Straw who stated that the

assurances were specific and detailed thus rendering them

sufficient to maintain the UK’s international

obligations51. In addition, the then Minister for Trade

Ian McCartney advocated their use, stating that the

assurances provided an additional layer protection over

and above the provisions of international instruments52.

Nevertheless, diplomatic assurances have received

significant criticism. INTERIGHTS and Amnesty

International have both stated that the reliance on such

assurances creates a dangerous loophole in non-

refoulement and ultimately erodes the absolute

prohibition on torture53. In addition, the Joint Committee

on Human Rights concluded that diplomatic assurances

could undermine established obligations and further, that50 ibid, above, No 37, p1451 Foreign Affairs Committee, Developments in the European Union,13 December 2005, HC 768(i)

52 HC Deb, 15 June 2006, c354WH53 Written submission to the European Court of Human Rights from Amnesty International Ltd., The Association For The Prevention of Torture, Human Rights Watch, INTERIGHTS, The International Commission of Jurists, OpenSociety Justice Initiative and Redress in the case of Ramzy v Netherlands

Student ID: 200771848 International Human Rights 2142 word count: 3,287there is a lack of remedies available on breach54.

Diplomatic assurances have also received academic

criticism. Manfred Nowak makes reference to cases such as

the USA’s deportation of Maher Arar to Syria55 and

Sweden’s deportation of Agiza and Alzery to Egypt, all

reliant on assurances and all failed to provide

sufficient protection56. Nowak concludes that the very

fact that these non-binding assurances are needed is

evidence that states are violating international law.

Moreover, he states that assurances are merely an attempt

by states to circumvent their obligations57.

However, despite such criticism states consistently seek

to rely on such assurances. Within the case of Othman v

UK58 the UK sought to deport an individual to Jordan

relying on an MOU. Within the courts judgment the MOU was

found to be sufficient enough to protect Othman from any

violations of his article three rights59. The court stated

that the MOU was specific and comprehensive as it

directly referred to Othman’s article three rights,

54 Joint Committee on Human Rights, The UN Convention on Torture, 19th Report of Session 2005-6, paragraphs 129 & 131 55 Arar v. Ashcroft, 414 F.Supp.2d 250 (E.D. N.Y. 2006)56 M. Nowak, above, No 2, pages 685 & 68657 ibid, p687 58 Othman (Abu Qatada) v. United Kingdom (Appl. No. 8139/09), Judgment of 17 January 2012, European Court of Human Rights (4th sect.)59 ECHR, Article 3 (freedom from torture and CIDT)

Student ID: 200771848 International Human Rights 2142 word count: 3,287further the assurance was unique in that it had withstood

examination by an independent tribunal60.

It may be said that international bodies such as the

European Court of Human rights, CAT and the HRC that

there is no attitude that places an outright ban on the

use of diplomatic assurances. Assurances have been found

to be insufficient in cases where the wording of them is

not comprehensive or specific enough to prevent

violations of the prohibition on torture. But, in cases

such as Othman it has been found that assurances may be

sufficient if they are specific and comprehensive. Thus

it may be concluded that diplomatic assurances offer

states a way of justifying deportation where there is a

risk of torture. Nevertheless, the countervailing

argument cannot be ignored. If the use of assurances were

to become an international norm then it could lead to the

erosion of the absolute nature of non-refoulement.

Moreover, if states such Jordan and Algeria (who are

signatories to UNCAT) cannot honour their international

obligations, what is there to say that they will honour

any bilateral agreement?

Conclusion

60 Othman (Abu Qatada) v. United Kingdom (Appl. No. 8139/09), Judgment of 17 January 2012, European Court of Human Rights (4th sect.) para 194

Student ID: 200771848 International Human Rights 2142 word count: 3,287We have seen human rights international instruments and

their respective bodies take an absolute prohibition

approach to torture in the non-refoulement context. That

said significant lacunas in said instruments have been

discussed. It may be concluded, that the failings of

these instruments allow signatory states to justify

deportation to face torture in extreme circumstances,

despite the absolute approach. Moreover, we have seen the

Refugee Convention run contrary to the absolute approach.

It may be said that the reasoning of the Refugee

Convention has provided a foundation from which states

have sought to justify their argument for a balanced

approach.

The cases of Suresh, Ramzy and Saadi have demonstrated

significant challenges to the absolute nature of non-

refoulement, thus calling into question its peremptory

status. Moreover, certain academics have taken a more

moral philosophical approach to this issue. Dershowitz

puts forward the argument that the prohibition of torture

when challenged by national security will inevitably come

second. And thus, authorising it in limited circumstances

creates accountability and transparency.

Further to the above, states have sought to rely on

diplomatic assurances. We have seen that despite

criticism as to their poor level of enforceability and

legitimacy, signatory states continue to rely on them,

Student ID: 200771848 International Human Rights 2142 word count: 3,287and use them as justification when deporting individuals

to countries with questionable human rights records.

It may be concluded that signatory states persistently

seek to justify deportation to face torture in national

security circumstances; despite the stance that non-

refoulement is non-derogable. However, it may also be

said that the case of Othman provides an example of a

movement, by international bodies, towards the use of

diplomatic assurances as the court accepted the assurance

stating it to be sufficiently specific enough to provide

safeguards against any risk of torture.

Student ID: 200771848 International Human Rights 2142 word count: 3,287

Bibliography

International Instruments

United Nations Convention against Torture and Other

Cruel, Inhuman or Degrading Treatment or Punishment 1984

International Covenant of Civil and Political Rights 1966

The Convention Relating to the Status of Refugees 1954

European Convention for the Protection of Human Rights

and Fundamental Freedoms 1950

HRC & CAT General Comments & Observations

GC20, HRI/GEN/1/Rev.1 (1994)

General Comment 2, CAT/C/GC/2/CRP.1/Rev.4, 23 Nov 2007

Concluding Observations of the Human Rights Committee,

Canada, U.N. Doc. CCPR/C/CAN/CO/5 (2006)

UN Docs CAT/C/SR.519 and 525

European Court of Human Rights Cases

Ireland v United Kingdom (1978) ECHR, Series A, No 25

Soering v UK (1989) ECHR, Series A, No161

Chahal v United Kingdom (1996) ECHR

Student ID: 200771848 International Human Rights 2142 word count: 3,287Ramzy v Netherlands, European Court of Human Rights,

Application No. 25424/05 (2008)

Saadi v Italy, European Court of Human Rights,

Application No. 37201/06,

Judgment of February 2008

Othman (Abu Qatada) v. United Kingdom (Appl. No.

8139/09), Judgment of 17 January 2012, European Court of

Human Rights (4th sect.)

Canadian & USA Cases

Suresh v Canada (Minister of Citizenship and

Immigration), Supreme Court of Canada [2002] SCC 1

Arar v. Ashcroft, 414 F.Supp.2d 250 (E.D. N.Y. 2006)

CAT & HRC Cases

Agiza v Sweden, Committee against Torture, UN Doc

CAT/C/34/D/233/2003

Alzery v Sweden, Human Rights Committee, UN Doc CCPR/C/88/D/1416/2005

Web Pages

https://newhumanist.org.uk/articles/4764/uk-to-deport-

pakistani-activist-who-has-received-taliban-death-

threats> accessed 1st January 15

http://www.alandershowitz.com/publications/docs/

torturewarrants2.html> accessed 2 January 15

http://articles.latimes.com/2001/nov/08/local/me-1494> accessed 2 January 15

Journal Articles

Student ID: 200771848 International Human Rights 2142 word count: 3,287Aoife Duffy. ‘Expulsion to Face Torture? Non-refoulement

in International Law’

M. Nowak, ‘Challenges to the absolute nature of the

Prohibition of Torture and ill-treatment’, Netherlands

Quarterly of Human Rights, 23 (2005)

Alexander Horne, Melanie Gower & Joanna Dawson, ‘Deportation of Individuals who may Face Torture’ House

of Commons publication, 2014

William F Schulz, ‘The Torturer’s Apprentice’, The

Nation, 2002

Others

Foreign Affairs Committee, Developments in the European Union, 13 December 2005, HC 768(i)

HC Deb, 15 June 2006, c354WH

Written submission to the European Court of Human Rights

from Amnesty International Ltd., The Association For The

Prevention of Torture, Human Rights Watch, INTERIGHTS,

The International Commission of Jurists, Open Society

Justice Initiative and Redress in the case of Ramzy v

Netherlands

Joint Committee on Human Rights, The UN Convention on Torture,

19th Report of Session 2005-6

Student ID: 200771848 International Human Rights 2142 word count: 3,287