CAT/C/70/D/915/2019 proceedings.6 Failure to do so prevents the Court from ruling on the case in full knowledge of the facts and may lead to a rejection of the application as abusive.7 4.7 Moreover, the State party submits that the complaint is inadmissible as manifestly unfounded under article 22 (2) of the Convention and rule 113 (b) of the rules of procedure. The State party recalls the Committee’s jurisprudence, according to which a complaint is manifestly unfounded when it lacks sufficient evidence to substantiate the claim. 8 With respect to the application of article 3 of the Convention, the burden of proof lies on the complainant, who must present an arguable case, by submitting substantiated arguments showing that the danger of being subjected to torture is foreseeable, present, personal and real.9 The State party recalls the complainant’s claims that the charges brought against him have a direct link with his anti-corruption activities and were motivated by revenge sought by the Governor of the Kaluga Province and the Kaluga Provincial Prosecutor, that the complainant and his family were threatened, that individuals in cars were waiting outside his apartment and his child’s school and that his extradition to the Russian Federation would expose him to a real risk of persecution, torture or ill-treatment. The State party submits that these claims are not supported by any documentation or evidence and that the complaint does not go beyond speculation, far-fetched assumptions and vast, meritless generalizations, even though it is unlikely that the complainant, as a former prosecutor, would be unable to present evidence of the telephone calls and texts. 4.8 The State party claims that the complainant refers only to general conditions of detention and patterns of human rights violations in the Russian penitentiary system. It notes, however, that, according to the Committee and the European Court of Human Rights, the existence of a pattern of gross, flagrant or mass violations of human rights in a country does not as such constitute sufficient reason for determining that a particular person would be in danger of being subjected to torture on return to that country; additional grounds must be adduced to show that the individual concerned would be personally at risk. 10 Further, the mere possibility of ill-treatment on account of an unsettled situation in the receiving country does not in itself give rise to a breach of the prohibition of torture; an applicant’s allegations require corroboration by other evidence than sources describing a general situation. 11 The State party submits that the present complaint contains no such additional grounds. 6 7 8 9 10 11 4 European Court of Human Rights, Bekauri v. Georgia, Application No. 14102/02, Judgment, 10 April 2012, para. 21; Popov v. Moldova, Application No. 74153/01, Judgment, 18 January 2005, para. 49; Akdivar and others v. Turkey, Application No. 21893/93, Judgment, 16 September 1996, paras. 53– 54. European Court of Human Rights, Mihailovs v. Latvia, Application No. 35939/10, Judgment, 22 January 2013, para. 97. R.S. v. Denmark (CAT/C/32/D/225/2003), para. 6.2; H.S.V. v. Sweden (CAT/C/32/D/229/2003), para. 8.3; R.T. v. Switzerland (CAT/C/35/D/242/2003), paras. 6.2–7; S.A. v. Sweden (CAT/C/32/D/243/2004), paras. 4.2–4.3; S.P.A. v. Canada (CAT/C/37/D/282/2005), para. 6.2; X. v. Switzerland (communication No. 17/1994), para. 4.2.; I.M. and V.Z. v. Denmark (CAT/C/57/D/593/2014), para. 6.3. Sivagnanaratnam v. Denmark (CAT/C/51/D/429/2010), paras. 10.5–10.6; A.R. v. Netherlands (CAT/C/31/D/203/2002), para. 7.3; Arthur Kasombola Kalonzo v. Canada (CAT/C/48/D/343/2008), para. 9.3; X. v. Denmark (CAT/C/53/D/458/2011), para. 9.3. See, inter alia, Kalinichenko v. Morocco; European Court of Human Rights, Mamatkulov and Askarov v. Turkey, Applications Nos. 46827/99 and 46951/99, Judgment, 4 February 2005, paras. 71–73; Oshlakov v. Russia, Application No. 56662/09, Judgment, 3 April 2014, para. 83. European Court of Human Rights, Vilvarajah and others v. United Kingdom of Great Britain and Northern Ireland, Applications Nos. 13163/87, 13164/87, 13165/87, 13447/87 and 13448/87, Judgment, 30 October 1991, para. 111; Fatgan Katani and others v. Germany, Application No. 67679/01, Decision, 31 May 2001; Chahal v. United Kingdom of Great Britain and Northern Ireland, Application No. 22414/93, Judgment, 15 November 1996, paras. 99–100; Müslim v. Turkey, Application No. 53566/99, Judgment, 26 April 2005, para. 67; Said v. Netherlands, Application No. 2345/02, Judgment, 5 July 2005, para. 54; Al-Moayad v. Germany, Application No. 35865/03, Decision, 20 February 2007, paras. 65–66; Saadi v. Italy Application No. 37201/06, Judgment, 28 February 2008, paras. 143–146; Puzan v. Ukraine Application No. 51243/08, Judgment, 18 February 2010, para. 34.