Part II lice, in relation to detained persons suspected of terrorism in Northern Ireland, of the “five techniques” (long-term hooding, subjection to noise, wall standing, deprivation of sleep and deprivation of food and drink other than bread and water). Although the European Commission of Human Rights considered the techniques to amount to torture, the Court qualified them only as inhuman and degrading treatment. In the rationale of its judgment, the Court emphasized that the techniques employed by the British police constituted severe and distressing treatment but they did not occasion suffering of the particular intensity, and therefore were considered inhuman treatment264. Only in the 1990s, in a number of cases against Turkey, the meaning and definitions of various forms of ill-treatment were significantly extended. It was considered necessary to consider various other aspects of the prohibition of torture (e.g. regarding deportation) in addition to those concerning treatment by the police or prison services. The ECHR also saw the necessity to impose on the states the obligation to develop procedures to protect citizens against such activities, as well as to carefully investigate allegations of torture and inhuman treatment. It was not until 20 years after the judgment in the case of Ireland that the interpretation of torture was extended. A  breakthrough judgment was issued in 1999 in the case Selmouni v. France265. It related to a several-hour interrogation of the detainee in police custody, during which he was beaten and forced into sexual acts. The ECHR found the police officers guilty of using torture against the detainee. It also emphasized that certain acts which were classified in the past as “inhuman and degrading treatment” as opposed to “torture” could be classified differently in future. 266 In its contemporary case law the Court considers torture to be deliberate inhuman treatment causing very serious and cruel suffering267. Inhuman treatment is one which is deliberately exercised for many hours and causes either physical injury or inflicts intense physical and mental suffering. Treatment may be described as degrading in the case of ill-treatment designed to arouse in victims feelings of fear, anguish and inferiority capable of humiliat Cf. S. Sykuna, Tortury w  XXI wieku [Torture in the 21st century], Wydawnictwo Uniwersytetu Gdańskiego, Gdańsk 2013, p. 171. 265 Selmouni v. France (complaint no. 00025803/94, judgment of 28.07.1999). 266 Cf. S. Sykuna, Tortury w  XXI wieku [Torture in the 21st century], Wydawnictwo Uniwersytetu Gdańskiego, Gdańsk 2013, p. 180. 267 Cf. Al Nashiri v. Poland case (application no. 28761/11, judgment of 24.07.2014). 264 91