52 OTHMAN (ABU QATADA) v. THE UNITED KINGDOM JUDGMENT Committee found that Algeria had failed to show why recourse to a military court was required in Madani’s case: the gravity or character of the offences was not sufficient. This conclusion meant that the Committee did not need to examine whether the military court, as a matter of fact, afforded the full guarantees of Article 14. THE LAW I. ALLEGED VIOLATION OF ARTICLE 3 OF THE CONVENTION 160. Relying on Article 3 of the Convention, the applicant complained that he would be at real risk of being subjected to torture or ill-treatment if deported to Jordan. Article 3 provides as follows: “No one shall be subjected to torture or to inhuman or degrading treatment or punishment.” A. The parties’ submissions 1. Government 161. The Government submitted that the materials on diplomatic assurances, which the applicant and third parties had provided (see paragraphs 141–146 above), all spoke of what the practice of courts should be, rather than the established requirements of the Convention. This Court’s approach had been to find that assurances were not in themselves sufficient to prevent ill-treatment; however, the Court would also examine whether such assurances provided in their practical application a sufficient guarantee against ill-treatment (see Babar Ahmad and Others v. the United Kingdom (dec.) nos. 24027/07, 11949/08 and 36742/08, § 106, 6 July 2010). Furthermore, contrary to the applicant’s submission (see paragraph 168 below), there was no principle in the Court’s case-law that, where there was a real risk of ill-treatment owing to systemic torture in the country of destination, assurances were incapable of eliminating that risk. 162. SIAC had followed the Court’s approach to assurances. It had received a wide variety of evidence, both as to the meaning and likely effect of the assurances and the current situation in Jordan. It had examined that evidence with great care in its determination. All the factors it had relied on in reaching its conclusions continued to apply with at least as much force as they did at the time of its determination. Its conclusions could not be altered by the critical reports which had been published since its determination;