OVERVIEW OF RELEVANT STANDARDS also explicitly deal with reasonable accommodation.104 Depending on the national context, the Committee has referred to: • the need to ensure access to healthcare on an equal footing with others, on the basis of their free and informed consent, and to the same level of health care as that provided in society at large; • repeal extrajudicial intervention programmes that involuntarily commit individuals to mental health establishments or force them to register with the mental health services; • ensure their participation in and access to all services and activities, on an equal basis with others, in prisons or other centres of detention; and • establish an independent formal complaints mechanism accessible to all persons detained in prisons or in forensic institutions. The UN Special Rapporteurs on Torture have taken different positions. Most pertinent are the positions of Manfred Nowak in his 2008 interim report105 and Juan Mendez, documented in the report on “Torture in Healthcare Settings: Reflections on the Special Rapporteur on Torture’s 2013 Thematic Report”.106 More specifically, the Special Rapporteur noted that: • Forced and non-consensual administration of psychiatric drugs, and in particular of neuroleptics, for the treatment of mental conditions (or chemical restraints) need to be closely scrutinised and ‘may constitute a form of torture or ill treatment. Such outcome will depend on the circumstances of the case and the suffering inflicted’.107 • The administration of electro convulsive therapy in its unmodified form (e.g., without anaesthetic and muscle relaxants) can no longer considered to be an acceptable medical practice and may constitute torture or ill-treatment. The administration of electroconvulsive therapy in its modified form is only acceptable with the 34 free and informed consent of the person concerned. • No therapeutic justification can be used for the use of solitary confinement and prolonged restraints of persons with disabilities in psychiatric institutions, which may amount to torture and ill-treatment. Mendez noted that any type of restraints of persons with disabilities in psychiatric institutions, regardless their duration, may amount to torture and ill-treatment. Other UN treaty bodies do not seem to go as far as the UNCRPD Committee in their recommendations. The UN Committee Against Torture (CAT Committee) has expressed its concern about the high number of persons with disabilities deprived of their liberty in social, medical and psychiatric institutions without their free and informed consent – including through the use of solitary confinement, restraints and forced medication, which may amount to inhumane and degrading treatment – and about the absence of legal safeguards.108 The CAT Committee, while accepting the possibility of lawful involuntary committal and involuntary treatment, has recommended ensuring effective supervision and monitoring, appropriate legal safeguards, proper training for medical and non-medical staff, and the use of de-institutionalization strategies and outpatient and community-based services.109 It has not adopted a consistent position on the provision by the person concerned of their free and informed consent to treatment and institutionalisation Inn the past, it has upheld a person's right to give or withhold their consent110 and has also allowed for third parties to provide it.111 A similar approach is adopted by the Human Rights Committee (HRC), which recommended that States put in place comprehensive procedures for seeking consent for the administration of psychiatric treatment. It recommends that States ensure that non-consensual psychiatric treatment may only be applied, if at all, in exceptional cases as a measure of last resort and when absolutely necessary to protect the health