Chapter 8 • International Legal Standards for the Protection of Persons Deprived of Their Liberty victims of ill-treatment and torture” contrary to article 5(1) and (2) of the American Convention on Human Rights.48 In the case of Castillo-Páez, involving the abduction and disappearance of the victim, the Inter-American Court of Human Rights concluded that it was contrary to the right to humane treatment guaranteed by article 5 to place Mr. Castillo-Páez in the trunk of an official vehicle, and that “even if no other physical or other maltreatment occurred, that action alone must be clearly considered to contravene the respect due to the inherent dignity of the human person.”49 ***** In the Irish case, the European Court of Human Rights concluded that the combined use of the five interrogation techniques of people arrested in Northern Ireland in 1971 constituted inhuman treatment within the meaning of article 3 of the European Convention on Human Rights. The Court found that these techniques, which consisted of wall standing, hooding, subjection to noise, deprivation of sleep, and deprivation of food and drink, “were applied in combination, with premeditation and for hours at a stretch” and that they “caused, if not actual bodily injury, at least intense physical and mental suffering to the persons subjected thereto and also led to acute psychiatric disturbances during interrogation”.50 In the view of the Court, these interrogation techniques were also “degrading since they were such as to arouse in their victims feelings of fear, anguish and inferiority capable of humiliating and debasing them and possibly breaking their physical or moral resistance”.51 In the case of Tomasi versus France, the applicant was subjected to police interrogation for about 40 hours, during which he had been “slapped, kicked, punched and given forearm blows, made to stand for long periods and without support, hands handcuffed behind the back; he had been spat upon, made to stand naked in front of an open window, deprived of food, threatened with a firearm and so on”.52 This constituted “inhuman and degrading treatment” to the European Court of Human Rights, the Court significantly adding that “the requirements of the investigation and the undeniable difficulties inherent in the fight against crime, particularly with regard to terrorism, cannot result in limits being placed on the protection to be afforded in respect of the physical integrity of individuals”.53 In the later case of Aksoy, the Court did however conclude that the applicant had been subjected to torture. In this case, the Court stated that “where an individual is taken into police custody in good health but is found to be injured at the time of release, it is incumbent on the State to provide a plausible explanation as to the causing of the injury, failing which a clear issue arises under Article 3 of the Convention.”54 Relying on 48 I-A Court HR, Villagrán Morales et al. case v. Guatemala, judgment of November 19, 1999, Series C, No. 63, p. 180, para. 177 read in conjunction with p. 176, para. 186; emphasis added. 49 I-A Court HR, Castillo-Páez case, judgment of November 3, 1997, in OAS doc. OAS/Ser.L/V/III.39, doc. 5, Annual Report Inter-American Court of Human Rights 1997, p. 264, para. 66. 50 Eur. Court HR, Case of Ireland v. the United Kingdom, judgment of 18 January 1978, Series A, No. 25, p. 66, para. 167. 51 Ibid., p. 66, para. 167; emphasis added. 52 Eur. Court HR, Case of Tomasi v. France, judgment of 27 August 1992, Series A, No. 241-A, p. 40, para. 108. 53 Ibid., p. 42, para. 115. 54 Eur. Court HR, Case of Aksoy v. Turkey, judgment of 18 December 1996, Reports 1996-VI, p. 2278, para. 61. Human Rights in the Administration of Justice: A Manual on Human Rights for Judges, Prosecutors and Lawyers 329