01185914 002/19-09-2007-ECCC/SC Doc No. F26/12 ECtHR, which has considered allegations of ill-treatment in deciding fairness of proceedings even in the absence of a formal complaint of torture. 82 42. A purely pragmatic justification for the exclusionary rule is that confessions or other information extracted through torture are intrinsically unreliable, as victims of torture are likely to say anything (whether true or not) in order to put an end to their torment. The intrinsic unreliability of such information was originally advanced in connection with arguments related to the right to a fair trial, as any conviction based on forced confessions would be unsafe. 83 Logically, however, the argument that evidence obtained through torture is unreliable is relevant not only to forced confessions but, more generally, to any information derived from a person subjected to torture, even if that person is not party to proceedings in which the information is to be used. 84 Of note is that a recent empirical study discredits the utility of the United States Central Intelligence Agency's "enhanced interrogation techniques" even for operative purposes, as it was found that they were not an effective means of acquiring intelligence, which lends further support to the argument that information obtained through torture is inherently unreliable. 85 use of forced confessions as evidence in courts is widespread in Cambodia; Consideration of Reports Submitted by States Parties Under Article 19 of the Convention: Report of Spain, CAT/C/SR.145, 23 August 1993, para. 8, "Paragraph 27 of the report [CAT/C/17/Add.l0] reproduced a judgement of the Constitutional Court of 15 April 1991, stating that ' ... each of the defendants was questioned on the specific and detailed contents of his statements to the police; the defendants used this opportunity to deny their original statements and allege that the statements in question were made under pressure and torture. This allegation of torture, which had not been made before, either by the defendant or the defence counsel present at the police proceedings, cannot be taken into account by this Court in order to invalidate the statements'. That judgement was completely at variance with the provisions of article 15 of the Convention, which stipulated that any statement which was established to have been made as a result of torture could not be invoked as evidence in any proceedings. If the provisions of the Convention were directly applicable in Spanish law, article 15 could, on the contrary, be used to invalidate evidence given during the proceedings". X2 Saunders v. United Kingdom, ECtHR, "Chamber Judgment", App. No. 19187/91, 17 December 1996, para. 71; Jalloh v. Germany, ECtHR, "Grand Chamber Judgment", App. No. 54810100, 11 July 2006 ("Jalloh v. Germany"), para. 100; Huseyn and Others v. Azerbaijan, ECtHR, "Chamber Judgment", App. Nos. 35485/05, 45553/05, 35680105 and 36085/05, 26 July 2011 ("Huseyn and Others v. Azerbaijan"), para. 202; citing mutatis mutandis Drs and Others v. Turkey, ECtHR, "Chamber Judgment", App. No. 46213/99,20 June 2006 ("Drs and Others v. Turkey"), para. 58, and Kolu v. Turkey, ECtHR, "Chamber Judgment", App. No. 35811/97, 2 August 2005 ("Kolu v. Turkey"), para. 54. X3 See Manfred Nowak & Elizabeth McArthur, The United Nations Convention Against Torture: A Commentary, p. 530; Soylemez v. Turkey, ECtHR, "Chamber Judgment", App. No. 46661/99, 21 September 2006, para. 122; Drs and Others v. Turkey, para. 60; Kolu v. Turkey, paras 51-54. X4 Huseyn and Others v. Azerbaijan, para. 202; El Haski v. Belgium, ECtHR, "Chamber Judgment", App. No. 649/08,25 September 2012 ("El Haski v. Belgium"), para. 85. X5 United States Senate Select Committee on Intelligence, Committee Study oj'the Central Intelligence Agency's Detention and Interrogation Program, 3 December 2014 (Declassification Revisions), p. 2, where the report finds that individuals subjected to such treatment either produced "no intelligence" or they "fabricated information, resulting in faulty intelligence". DECISION ON OBJECTIONS TO DOCUMENT LISTS - FULL REASONS 19/40