Home > Genocide and Crimes Against Humanity > Torture

Torture—the infliction of severe physical or mental suffering—is frequently a component of systematic policies and attacks against individuals or groups, in peacetime or in time of war. Torture is used variously as a weapon of war, as a means of soliciting information or confession, as a technique to humiliate or punish, as a tool of repression or intimidation, and as a form of sexual violence. Its typical victims include political opponents; particular national, racial, ethnic, religious or other groups; women; prisoners of war; detainees; and ordinary criminal suspects.

In response, international law has prohibited torture and other cruel, inhuman or degrading treatment in absolute terms. The prohibition of torture and other forms of ill treatment ranks among the most firmly entrenched principles of international law regarding human rights and of international humanitarian law. The right not to be tortured is based on the principles of human dignity and integrity of the person that underlie these bodies of law.

Torture is also considered a crime under international law. It is one of a small number of acts considered so heinous that all countries must play their part in pursuing the perpetrators. As a U.S. court ruled in the landmark case of Filartiga v. Peña-Irala, "the torturer has become—like the pirate and slave trader before him—hostis humani generic, an enemy of all mankind."

International and National Norms Prohibiting Torture and Other Ill-Treatment

International legal norms prohibiting torture and other forms of ill-treatment have developed, largely since 1945, as central components of the international law of human rights, international humanitarian law, and international criminal law. The Universal Declaration on Human Rights (UDHR) of 1948 includes freedom from torture as one of the fundamental rights belonging to all human beings. Article 5 of the declaration provides that "No one shall be subjected to torture or to cruel, inhuman, or degrading treatment or punishment." Subsequently, identical or similarly worded prohibitions were included in human rights treaties adopted at international and regional levels, and these set legal standards for individual governments to follow. These include Article 7 of the International Covenant on Civil and Political Rights (ICCPR) of 1966, Article 3 of the European Convention on Human Rights of 1950, Article 5 of the American Convention on Human Rights of 1969, and Article 5 of the African Charter on Human and Peoples' Rights of 1981.

These treaties oblige states to refrain from torture or other prohibited treatment, and establish mechanisms for making states accountable if their officials commit such abuses. The prohibition on torture is absolute, and allows for no exceptions. In human rights treaties, torture is invariably listed as a "non-derogable" right. States must never deviate from the prohibition on torture, even, according to Article 4 of the ICCPR, "in time of public emergency which threatens the life of the nation."

A major landmark was the 1984 conclusion of a treaty aimed specifically at stamping out torture: the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (otherwise known as the Torture Convention). By March 2004, this convention had 134 state signatories. The Torture Convention set out specific measures that governments must take to prevent and punish torture, and established its Committee Against Torture to monitor states' compliance and to receive individual complaints.

Regional torture-specific instruments followed. In 1985, the Inter-American Convention to Prevent and Punish Torture came into effect. The European Convention for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment passed into law in 1987, followed by the Robben Island Guidelines on the prevention of torture and ill treatment in Africa in 2002. Under UN auspices, sets of guidelines were developed that aimed at preventing torture. Among these were the UN Code of Conduct for Law Enforcement Officials of 1979 and the UN Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment of 1988.

In parallel to these developments in the sphere of human rights, norms prohibiting torture and other illtreatment also developed in the spheres of international humanitarian law, and the laws of war. The four Geneva Conventions of 1949 list torture and inhuman treatment committed during international armed conflict that are considered grave breaches of the Geneva Conventions (war crimes). Article 3, common to all four of the Geneva Conventions, as well as the second Additional Protocol II to those conventions hold torture and cruel, humiliating. and degrading treatment as prohibited by the law applying to internal armed conflicts.

As the concept of crimes against humanity developed in the wake of World War II atrocities, torture was considered to be covered, although not listed explicitly, in early definitions. The Nuremberg and Tokyo Charters of 1945 and 1946, on which trials of German and Japanese World War II leaders were based, included within their definitions of prosecutable crimes against humanity "other inhumane acts committed against any civilian population." The Control Council Law No. 10 of 1945, used as the basis for prosecuting second-tier Nazis, specifically listed torture as one of the inhumane acts constituting a crime against humanity.

When the International Criminal Tribunal for Former Yugoslavia (ICTY) was established by the UN in 1993, its statute listed torture as among the crimes against humanity that the tribunal could prosecute. The 1994 statute of the International Criminal Tribunal for Rwanda (ICTR) followed suit. The Rome Statute for the International Criminal Court (ICC), which was concluded in 1998, codified crimes against humanity in greater detail. Article 7 of that statute includes the widespread or systematic practice of torture as a crime against humanity, when such practices are committed as part of an attack directed against a civilian population. Also listed are "[o]ther inhumane acts of a similar character internationally causing great suffering or serious injury to body or to mental or physical health."

Torture is also one of the acts that can constitute the crime of genocide. The definition adopted in the Genocide Convention of 1948 included, at Article II(b), "causing serious bodily or mental harm." This definition was intended to cover a range of acts of physical violence falling short of actual killing, as well as acts causing serious mental harm. The ICTR helped to clarify the meaning of this phrase in 1998 in the Akayesu case, finding that the definition of serious bodily or mental harm, includes acts of torture, be they bodily or mental, and inhumane or degrading treatment and persecution, and could include rape and other acts of sexual violence or death threats. The Rome Statute included a document that set out the physical and mental elements of each crime that needed to be proved in any given case brought before the ICC. This document, titled "Elements of Crimes" contains the following footnote to the crime of genocide by causing serious bodily or mental harm: "This conduct may include, but is not necessarily restricted to, acts of torture, rape, sexual violence or inhuman or degrading treatment."

The absolute prohibition on torture is has been generally accepted as a part of customary international law, and is therefore binding on all states, not only those that become party to treaties prohibiting torture. This view has been upheld by international courts and tribunals, as well as by national courts. The prohibition has also been recognized as a norm of jus cogens, which is an overriding or superior principle of international law.

Torture and other ill-treatment are also specifically prohibited in many national constitutions. Even where a prohibition on torture is not specifically included in the constitution, it has been made into other provisions. For instance, by giving a wide interpretation to the right to life and personal liberty, the Indian Supreme Court has incorporated freedom from torture among its schedule of constitutionally protected rights. Many states have made torture a specific criminal offence under their penal codes. Torture is also commonly criminalized in military codes and through legislation incorporating the war crimes provisions of the Geneva Conventions. After becoming party to the Rome Statute for the ICC, states have also incorporated torture as a crime against humanity, as genocide, and as a war crime in their domestic law.

The international norms in this array of treaties and customary international law impose a range of obligations on states. For instance, states must not only refrain from using torture, they must also take strong positive measures to prevent and punish torture. Article 2.1 of the Torture Convention obliges states to "take effective legislative, administrative, judicial or other measures to prevent acts of torture in any territory under its jurisdiction." Such measures include training law enforcement personnel and other public officials and reviewing rules and practices relating to the interrogation and custody of prisoners and detainees. States must also ensure that statements taken as a result of torture may not be used in court as evidence, except against a person accused of torture as evidence that the statement was made.

States also have an obligation to investigate and prosecute individuals responsible for torture. Under Article 4 of the Torture Convention, states are obliged to ensure that all acts of torture are criminal offences under domestic criminal law, and to impose penalties that reflect their grave nature. States are obliged to carry out a prompt and impartial investigation whenever torture or ill-treatment is alleged, to identify those responsible, and to impose an appropriate punishment, as illustrated in the case of Velasquez Rodriguez v. Honduras, tried before the Inter American Court of Human Rights in 1988.

The duty of states to ensure that torturers are brought to justice is not limited to policing what happens within their own borders, since torture is also a crime under international law. According to Articles 5.2 and 7 of the Torture Convention, when an alleged torturer is present within its jurisdiction, regardless of where the torture was committed, a state must either prosecute the person, or extradite them elsewhere to face trial. This exceptional jurisdiction—based only on the nature of the crime itself, regardless of where the crime was committed or by whom—is recognized in international law and is known as universal jurisdiction. The "extradite or prosecute" formula exists also in the Geneva Conventions in relation to grave breaches, thus applying to those who commit torture in the course of an international armed conflict. Even outside the scope of these treaties, states have the right, and may be obliged, under international law to prosecute torture on the basis of universal jurisdiction. There is increasing authority for the proposition that customary international law requires states to prosecute all crimes against humanity, genocide, and war crimes, and that this extends to war crimes committed in internal armed conflict, to individual acts of official torture, and possibly also to cruel or inhuman treatment.

The duty to prosecute torture, and its status as a crime under international law, has a number of important implications. There is increasing consensus that amnesties should not be granted for torture, nor should the normal rules on statutes of limitations or immunities be applied in cases of torture. For instance, the British House of Lords ruled in March 1999 that Augusto Pinochet was not entitled to head-of-state immunity for torture from the time that the Torture Convention applied.

According to Article 13 of the Torture Convention, states must provide access to adequate remedies for victims when torture occurs. Any individual who alleges they have been tortured must have the right to complain to competent authorities, and to have the allegation promptly and impartially examined. Further, victims have a right to reparation, including compensation, restitution, rehabilitation, "satisfaction" (which may include bringing to account those responsible and symbolic measures such as commemorations), and guarantees that torture will not recur. These victim's rights are laid out in a UN draft document regarding the basic principles and guidelines on the right to a remedy and reparation for victims of violations of international human rights law and violations of international humanitarian law, as revised October 2003. Finally, the duty to protect people from torture and other ill treatment extends to the duty not to hand them over to be tortured elsewhere. Article 3 of the Torture Convention prohibits states from expelling, returning, or extraditing a person to another state where there are substantial grounds for believing they could be subjected to torture or other prohibited treatment there.

Definitions of Torture

Torture is absolutely prohibited in all circumstances. But what is it? A common element that appears consistently in definitions is that torture is the intentional infliction of severe pain or suffering, whether physical or mental, on a person. Decisions of international human rights courts and monitoring bodies have been very influential in establishing the basic elements of the definition. International criminal tribunals have relied heavily on these decisions to interpret what constitutes torture when it is being prosecuted as a crime against humanity or as a genocidal act, although they have also departed from the international human rights law interpretations in significant aspects.

The severity or intensity of pain or suffering caused is one factor that will determine whether behavior amounts to torture. An act has to cause "very serious and cruel suffering" to constitute torture, as the European Court of Human Rights decided when called upon to consider whether certain techniques used by U.K. security forces while interrogating IRA suspects in Northern Ireland were lawful (Ireland v. U.K.). The court concluded, in its judgment of 1978, that the techniques (hooding; being made to stand against a wall for many hours; subjection to constant noise; and deprivation of sleep, food and drink) were not severe enough to constitute torture, but did constitute inhuman treatment, which is also prohibited under the Torture Convention. The ICTY also followed this approach, finding that the severity of pain or suffering is what sets torture apart from other crimes. Subjective as well as objective factors may be considered in assessing severity. The European Court of Human Rights takes into account all the circumstances, including the duration of the treatment; its physical and mental effects; and the sex, age, and state of health of the victim. The ICTY has also said that subjective as well as objective criteria may be relevant in assessing the gravity of the harm.

As for the definition of mental torture, once again international cases have helped to clarify how to assess whether mental suffering caused by a certain act is severe enough to amount to torture. In the case of Estrella v. Uruguay, in 1980, the Human Rights Committee found that mock amputation of the hands of a well-known guitarist was psychological torture.

Another factor that distinguishes torture from other ill-treatment in the international law of human rights is the purpose for which the particular suffering is inflicted. In human rights law, exemplified in Article 1 of the Torture Convention, in order for conduct to amount to torture, it must be inflicted for specific purposes such as obtaining information or a confession, punishment, intimidation, coercion, or discrimination. The European Commission of Human Rights had already established the need for such a purpose in its 1969 decision in a case concerning the conduct of Greek security forces following the military coup. This legal decision, following what came to be known as the "Greek case," confirmed that without such a purpose, the same act would be classified as ill treatment but not torture. The European Court of Human Rights has continued to look for specific purposes before it will categorize an act as torture, for example, in the 1996 case of Aksoy v. Turkey. The Israeli Supreme Court, when considering methods used by Israeli security services in interrogating Palestinian suspects in 1999, distinguished between a situation in which sleep deprivation is a side effect inherent in interrogation, which would not be unlawful, and a situation where prolonged sleep deprivation is used as an end in itself, for the purpose of tiring or breaking the prisoner, in which case it would not be lawful.

In international criminal law, however, the requirement of a particular purpose appears to be losing ground. In cases concerning torture as a crime against humanity, although the ICTY and ICTR have held that the act or omission must aim at purposes such as those outlined in Article 1 of the Torture Convention, (e.g., the ICTR in the Akayesu case, 1998), they have also said that this is not to be viewed as an exhaustive list, and that the prohibited purpose need not be the predominating or sole purpose. In a further departure, in the Rome Statute's "Elements of Crimes," a footnote to the elements of the crime against humanity of torture states that: "It is understood that no specific purpose need be proved for this crime."

Another difference has opened up between human rights law and international criminal law as regards the state-actor requirement. The Torture Convention requires an act of torture to have been "inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting in an official capacity." The rule reflects the traditional purpose of human rights protection, which is to place limits on abuses by states rather than to regulate behavior between private individuals. This approach has shown signs of breaking down in some respects, however. For instance, states are increasingly required to regulate private individuals' behavior in order to protect vulnerable people from ill treatment. In the sphere of international criminal law, non-state actors can be held responsible for torture. The ICTY decided that the definition of torture in the context of crimes against humanity is not identical to the definition in the Torture Convention, and that outside the framework of the Torture Convention, customary international law does not impose a public official requirement in relation to criminal responsibility for torture.

Special elements are added to the crime of torture if it is prosecuted as a crime against humanity, an act of genocide, or a war crime. For example, as a crime against humanity under the Rome Statute, torture must be carried out as part of a widespread or systematic attack against a civilian population, accompanied by the knowledge or intention to further such an attack, and it must be inflicted upon a person in the custody or under the control of the accused. When prosecuted as an act of genocide, the serious bodily or mental harm must be caused to persons belonging to a particular national, ethnical, racial or religious group, and the perpetrator must have intended to destroy that group, in whole or in part. The conduct must either be part of a "manifest pattern of similar conduct" against such a group, or be itself capable of causing such destruction of the group.

The international criminal tribunals have been instrumental in expanding understandings of the definition of torture, for instance, by prosecuting rape and other forms of sexual violence under the heading of torture as a crime against humanity. The ICTY Appeals Chamber has said that, since sexual violence necessarily gives rise to severe pain or suffering, the crime of torture has been established once rape has been proved.

Definitions of Inhuman and Degrading Treatment or Punishment

Again, interpretations of these terms have developed in the law of human rights. Treatment causing less severe suffering, or not for one of the requisite purposes, may nonetheless constitute inhuman or degrading treatment. Solitary confinement, incommunicado detention, and poor prison conditions are examples of behavior that may amount to inhuman treatment, depending on the circumstances. For example, in Ôcalan v. Turkey, the European Court of Human Rights found in 2003 that complete sensory isolation, coupled with total social isolation, can destroy the personality and would constitute inhuman treatment. On the other hand, it held that merely prohibiting contact with other prisoners for legitimate reasons such as security does not in itself amount to a violation. In the Greek case, treatment was found to be degrading if it grossly humiliates a person before others, or if it drives a person to act against his or her will or conscience. International criminal tribunals have generally followed these interpretations. In the ICTY and ICTR, using persons as human shields is an example of behavior that has been found to constitute inhuman or cruel treatment.

The definitions of torture and other forms of prohibited treatment, and the boundaries between such various forms of treatment, tend to be somewhat fluid and to change over time. According to the European Court of Human Rights, in its findings in Ireland v. U.K., the distinction between torture and other forms of prohibited treatment was embodied in the Torture Convention in order to allow the special stigma of torture to attach only to deliberate inhuman treatment causing very serious and cruel suffering. The European Court has also consciously amended its standards over the years, classifying as torture acts which it had previously viewed as inhuman treatment in the past. An example of this shift in classification can be seen in the 1999 case of Selmouni v. France.

Sanctions

How does the prohibition on torture and other illtreatment affect what forms of punishment states may impose, given that the Torture Convention says that torture "does not include pain or suffering arising only from, inherent in, or incidental to lawful sanctions"? The same exclusion appears as part of the definition of torture as a crime against humanity applying in the ICTY, ICTR, and ICC. The main reason for the exclusion is to make clear that punishments such as imprisonment, which might otherwise be challenged on the basis they cause severe suffering, do not constitute torture. The question is to what extent this leaves open the door for other punishments that would otherwise fall foul of the definition but are permitted under national law. Some argue that the phrase rightly leaves what constitutes cruel, inhuman, or degrading treatment or punishment to be determined by the moral and legal standards in each society. Under Islamic shari'a law, theft is punishable by amputation of the right hand, and in certain countries, corporal punishments are administered by the courts. Some national courts have ruled that corporal punishments such as whipping and flogging violate the prohibition on torture or illtreatment. Examples are Botswana, Zimbabwe, Namibia, South Africa, and St. Vincent and the Grenadines. In Tyrer v. U.K., the European Court of Human Rights found that the punishment of birching (a type of flogging) ordered by a juvenile court was a degrading punishment. The UN Special Rapporteur on Torture reported to the Commission on Human Rights in 1997 that, in his view, corporal punishment violates the prohibition on torture or cruel, inhuman, or degrading treatment or punishment. Further, punishments are subject to scrutiny according to international standards. Subsequently, the commission adopted a Resolution 1997/38, which stated that corporal punishment can amount to cruel, inhuman, or degrading punishment or even to torture. Corporal punishment is prohibited in the Geneva Conventions in relation to prisoners of war or protected civilians in international armed conflict.

The courts of several countries, including Tanzania, Canada, Hungary, and South Africa, have held that the death penalty violates constitutional prohibitions on torture and other forms of ill-treatment. In the Ôcalan case, the European Court of Human Rights in 2003 declined to reach a firm conclusion on whether the death penalty was inhuman and degrading in all circumstances, but found that its imposition following an unfair trial did amount to inhuman treatment. The prohibition on torture also places limitations on how the death penalty is implemented. In 1994, the Judicial Committee of the Privy Council, the highest court of appeal for Jamaica, ruled that to carry out executions after 14 years of delay would violate the Jamaican constitution, and that after five years on death row, a prisoner would have suffered inhuman punishment (Pratt and Morgan v. Attorney General for Jamaica).

Psychological Impact of Torture

Both physical and mental torture can have lasting psychological effects. In serious cases, post-traumatic stress disorder (PTSD) can be diagnosed. Criteria for PTSD include re-experiencing aspects of a traumatic event in nightmares or flashbacks, avoidance of reminders of the event, sleep problems, memory and concentration problems, anger, and low mood. However, the concept of PTSD is somewhat controversial among mental health experts, and some (such as Derek Summerfield) do not accept that there is a psychiatric illness that is specific of trauma or torture. Such dissenting experts view the reframing of distress as a psychological disturbance to be a distortion, and prefer to look for solutions in a broader social recovery.

Because of the widespread use of torture and the particular needs of those who survive it, specialized torture rehabilitation centers have sprung up all around the world that provide physical and psychological treatment for survivors of torture. Some of these are in the countries where torture is taking place, and others cater primarily for refugee communities. The UN in 1981 established the UN Voluntary Fund for Victims of Torture to provide humanitarian assistance through medical, legal, and other forms of support to torture victims and their families.

International law has increasingly recognized that the psychological impact of torture calls for particular legal remedies. In international standards that are developing on the right to reparation, rehabilitation—including medical and psychological care as well as legal and social services—is specifically identified as one of the forms of reparation to which victims of violations will be entitled. This perspective is explicitly embodied in the UN Draft Basic Principles and Guidelines on the Right to a Remedy and Reparation.

Action of International Institutions and International Jurisdictions against Torture

Monitoring states' records on torture and holding them accountable is the function of international human rights treaty bodies. Among these bodies is the UN Committee Against Torture, established under the Torture Convention, which requires member states to submit regular reports on what they are doing to comply with the treaty, and issues observations and recommendations in response. Although the Committee Against Torture lacks enforcement powers and is frequently frustrated by states' late reporting, most states that are party to the Torture Convention do submit reports and appear before the committee to defend their records. The UN Commission on Human Rights has also taken steps specifically targeting torture. Its Special Rapporteur on Torture takes up cases of alleged torture with governments, carries out country visits, and reports annually to the Human Rights Commission. These mechanisms are designed to respond both to individual or isolated acts and to systematic torture.

Procedures have also been developed specifically to address situations where torture is committed as part of a widespread or systematic pattern of violations. Under Article 20 of the Torture Convention, there is established a confidential inquiry mechanism that allows the committee to look into information that torture is being systematically practiced in a member state. The UN Commission on Human Rights also has a confidential procedure (known as the 1503 Procedure) for considering information pointing toward a consistent pattern of gross and systematic violations. If, after examining the situation, a special working group believes further steps are needed, it can turn the matter over for more public consideration by the commission. This procedure was revised following a review in 2000, in response to the widely held view that it was ineffective.

Individual complaint mechanisms established at regional and international levels have been important in revealing places where systematic torture is taking place, as well as in providing redress for individual victims. United Nations' treaty bodies, including the Committee Against Torture, receive complaints from individuals, but only against states that have agreed to such complaints being referred. The treaty bodies also issue non-binding decisions on whether a violation has taken place. Regional human rights courts, such as the European and Inter-American Courts of Human Rights, have played a leading role in defining torture and other forms of ill-treatment, and have issued many judgments declaring that a violation has occurred and ordering compensation to individual torture victims. However since the remedies they order are directed at the individuals whose cases are before them, these courts have not been able to deal directly with the underlying causes of widespread or systematic torture. Nevertheless, their findings can help to reveal the problem, and may help bring about international pressure for change.

International inspection mechanisms have been established that aim to prevent torture by addressing the conditions it which it occurs. The European Committee for the Protection of Torture and Inhuman or Degrading Treatment or Punishment (the ECPT) operates within Europe and is designed to bring about improvements in conditions in which prisoners and detainees are held. This committee conducts regular inspections of places of detention within its member states, and also makes ad hoc, unscheduled visits in response to specific concerns. After a visit, the committee reports its findings to the state in which the detentions are occurring, and gives that state an opportunity to respond. Normally, the state allows the report to be made public. In 2002, a new Optional Protocol to the UN Convention against Torture was adopted by the UN General Assembly, establishing a similar system of international inspection of places of detention for states that are party to the Convention and that have signed up for participation in the inspection program.

The international community has also taken collective action to hold individuals criminally accountable for torture, along with other crimes under international law. Since the Nuremberg trials, international law has recognized torture in its occurrence as a crime against humanity, but there have been relatively few prosecutions either at the international or national level until the establishment of the ICTY and the ICTR in the 1990s. Torture and ill treatment were prosecuted in some of the post–World War II trials. One example was the "High Command Case" brought by the U.S. against fourteen Nazi defendants in Germany in the 1940s. Torture was singled out by the international commissions of experts that convinced the UN Security Council to establish the ICTY, the ICTR, and, in 2000, the Special Panels in East Timor. It was also one of the violations that spurred the UN to agree to work together with the government of Sierra Leone to establish the Special Court there in 2002. Numerous indictments for torture have been handed down by these judicial institutions.

There are also examples of countries prosecuting torture as part of an attempt to deal with atrocities in their own past. Klaus Barbie, head of the Gestapo in Paris during the Nazi occupation of France in World War II, was tried in a French criminal court in 1987 for crimes against humanity committed in France during the war, in which acts of torture featured prominently. He was sentenced to life imprisonment. Truth-seeking mechanisms, such as national truth commissions, have also investigated widespread torture. In its report of 2003, the Peruvian Truth Commission concluded that during the period 1983 to 1997 there was a widespread practice of torture by state officials that amounted to crimes against humanity, and recommended that criminal charges be brought against those responsible.

The 1990s saw a significant increase in action by individual states to pursue alleged torturers for acts committed outside their territory, relying either on universal jurisdiction or other permissible bases of jurisdiction, such as the nationality of the victim. The number of states that had amended their law to provide a jurisdictional basis for their courts to prosecute torture committed elsewhere, and the number of actual prosecutions, steadily increased. In 1994 a Danish court convicted Refik Saric under the Geneva Conventions for torturing detainees in a Croat-run prison camp in Bosnia in 1993, and sentenced him to eight years imprisonment. A Spanish court charged former Chilean President Augusto Pinochet with committing torture in Chile, and sought his extradition from the U.K. in 1998. That process was stopped, not due to any jurisdictional impediment, but because Pinochet was found to be unfit to stand trial. Complaints including torture have also been pursued in the courts of several European countries, including Belgium, France, the Netherlands, and Senegal, involving alleged torture in Chad, Mauritania, Rwanda, Algeria, Tunisia, Suriname, Chile, and Argentina.

SEE ALSO Conventions Against Torture and Other Cruel, Inhuman, and Degrading Treatment; Prosecution; Psychology of Perpetrators; Psychology of Victims; Reparations

Fiona McKay