57 avenues for accountability including judicial and administrative sanctions against those responsible.326 Optional Protocol to the Convention, as well as other treaties. Satisfaction has been frequently ordered in human rights jurisprudence to address injuries which involve breaches of trust, in which acknowledgement and commemoration may help to contribute to an effective remedy.327 Criminal investigations have also been ordered as satisfaction. Cessation, as a form of satisfaction, has been emphasised as a remedy for continuing violations. For example, in cases of disappearance, full disclosure of the truth, and the need to locate and identify remains, is understood to be central.328 States are regularly being asked to take active steps to prevent torture and other prohibited ill-treatment, which usually requires them to take a range of legislative, educative and practical measures to outlaw the practice, including ending impunity. Guarantees of non repetition include: strengthening monitoring mechanisms and other procedural safeguards applicable to detainees and others who come into contact with authorities; strengthening policies and legislation; vetting public officials; and setting up commissions of inquiry to investigate wide-scale occurrences of torture. VII.2.5 Guarantees of non-repetition Reducing the reliance on confession-based evidence and other, similar recommendations that have been made by the Special Rapporteur on Torture329 are important ways in which states can reduce the incentive to coerce statements from detainees. This, in turn, will help to reduce the practice of torture. The prevention of torture is a clear component of the overall prohibition on torture and an important part of the UN Convention Against Torture and the 300 Arzate case, Mexican Supreme Court of Justice, Amparo Review No. 703/2012. 301 Judgment of the Spanish Supreme Court No. 737/2009 (Criminal Division) of 6 July 2009, legal basis number four, para 29. 302 For example, Judgment of the Spanish Constitutional Court No. 7/2004 of 9 February 2004. The Spanish Constitutional Court considered that the declarations made before the investigating judge were flawed by the torture previously suffered by the accused. Consequently, the evidence was excluded. However, the accused were ultimately convicted on the basis of other evidence that was independent from the declarations obtained by torture. See similarly, Mexican Supreme Court of Justice, Direct Amparo Review, No. 6564/2015. 303 R v Latif [1996] 1 WLR 104, para 112-113. 304 R v Horseferry Road Magistrates’ Court, Ex p Bennett [1994] 1 AC 42, para 76C. 305 Including (a) Where a fair trial is impossible, for example because of delays or adverse media publicity (R v Stone [2001] Crim. L.R. 465); (b) where the UK authorities were involved in the unlawful abduction of a person from a third country to the United Kingdom (also known as ‘rendition’) in order to face trial, even where there was no question that the subsequent trial was fair (R v Horseferry Road Magistrates’ Court, Ex p Bennett [1994] 1 AC 42 (involving a person abducted from South Africa in gross breach of his rights and the law of South Africa) and R v Mullen [2000] QB 520 (involving the appeal against conviction for a serious terrorist offence following the suspect’s illegal abduction from Zimbabwe)); (c) Where the state has procured the commission of a crime through entrapment (R v Looseley, Attorney General’s Reference (No 3 of 2000) [2001] UKHL 53). 306 See generally, UN Human Rights Committee (HRC), General Comment no. 31, the Nature of the Legal Obligation on States Parties to the Covenant, 26 May 2004, CCPR/C/21/Rev.1/Add.13. 307 UN General Assembly, Convention Against Torture, Article 14; UN Committee Against Torture, General Comment No. 3 (2012): Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment: implementation of article 14 by States parties, 13 December 2012, CAT/C/GC/3. 308 Ndiki Mutua and Others v The Foreign and Commonwealth Office [2012] EWHC 2678 (QB). 309 Wachira Weheire v The Attorney General [2010] eKLR, 21 July 2010 (Kenya); D.K. Basu v State of West Bengal, AIR 1997 SC 610 (India); Dr. Mehmood Nayyar Azam v State of Chattisgarh and Ors (Civil Appeal No. 5703 of 2012) [2012] 8 SCR 651, 3 Aug. 2012 (India). 310 For example, Nepal: Compensation for Torture Act, 2053, 18 December 1996; USA: Torture Victim Protection Act 28 U.S.C. 1350 (1991). 311 For example, Philippines Compensation Act to Victims of Human Rights Violations, H. No. 5990, 25 Feb. 2013; Chilean Law No. 19.992 Establece pension de reparacion y otorga otros beneficios, 17 Dec. 2004, modified 10 Dec. 2009; Argentinean Law No. 24.043 of 1991. 312 For example, Guridi v Spain, where the UN Committee Against Torture recognised that in the particular case, reparation for torture needed to ‘cover all the damages suffered by the victim, which includes, among other measures, restitution, compensation, and rehabilitation of the victim, as well as measures to guarantee the non repetition of the violations, always bearing in mind the circumstances of each case’ (UN Committee Against Torture, thirty-fourth session, CAT/C/34/D/212/2002, para 6.8). 313 An emphasis of the Nairobi Declaration on Women’s and Girls’ Right to a Remedy and Reparation (International Meeting on Women’s and Girls’ Right to a Remedy and Reparation, Nairobi, 19-21 March 2007). 314 Arrest Warrant of 11 April 2000 (DRC v Belgium) (Merits) [2002] ICJ Rep 3. 315 Cantoral Benavides v Peru (Reparations and Costs) Ser C no 88 (IACtHR, 3 December 2001), para 78. 316 Loayza Tamayo v Peru (Merits) Ser C no 33 (IACtHR, 17 September 1997), para 84. 317 Fermín Ramírez v Guatemala (Merits, Reparations, Costs) Ser C no 126 (IACtHR, 20 June 2005), para 130(c). 318 Appeal # 2.0000.00.406378-5/000 of the Court of Appeals of the State of Minas Gerais [2004]. 319 Convention against Torture, Article 14. 320 Plan de Sánchez Massacre v Guatemala (Reparations) Ser C no 116 (IACtHR, 19 November 2004), para 106-8. 321 Juvenile Reeducation Institute v Paraguay (Preliminary Objections, Merits, Reparations and Costs) Ser C no 112 (IACtHR, 2 September 2004), para 340(13).