Part II was mocked with an electrically powered drill; the applicant was forced to stand naked in his cell, with a hood on his head. The complainant was also subjected to something that was described as potentially harmful stress position. It meant that he had to kneel on the floor and lean back. He was also placed in standing stress positions, was pushed, and pulled up from the floor by his shoulders tied on his back with a belt. This could have caused at least shoulder dislocation. He was threatened with his female family members being abused in front of him. With the intention to cause pain, the complainant was also washed with a rigid brush that is normally used ... to peel off dirt that is hard to remove272. In the light of the above, the Court held that the treatment to which the applicants had been subjected while in the CIA custody in Poland constituted torture within the meaning of Article 3 of the Convention. As regards violation of Article 3 of the Convention by way of inhuman or degrading treatment or punishment, most of the cases concerned: conditions in which the penalty of imprisonment was served (lack of adequate medical care, overcrowding, long-term isolation, and regime used for dangerous prisoners)273; treatment by the police274 and treatment in sobering-up stations275. Analysis of the ECHR judgments shows that despite the existence of numerous safeguarding systems, cases of torture and inhuman treatment still take place. The application lodging system is centred primarily on reacting to situations that have occurred. It allows to assess a  given situation and determine the methods of action only after the use of torture or other inhuman or degrading treatment has been disclosed, and thus it fails to work in a preventive manner. Such an approach has led to the search for legislative solutions that protect human rights more strongly. On 26 November 1987, the European Convention for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment276 was drawn up in Strasbourg, gen Cf. Al Nashiri v. Poland (application no. 28761/11, judgment of 24 July 2014, point 511. Case examples: Chyła v. Poland, application no. 8384/08, judgment of 3.11.2015; Klibisz v. Poland, application no. 2235/02, judgment of 4.10.2016; Janusz Wojciechowski v. Poland, application no. 54511/11, judgment of 28.06.2016; Pugžlys v. Poland, application no. 446/10, judgment of 14.06.2016; Karwowski v. Poland, application no. 29869/13, judgment of 19.04.2016. 274 Case examples: Lewandowski and Lewandowska v. Poland, application no. 15562/02, judgment of 13.01.2009; Artur Mrozowski v. Poland, application no. 9258/04, judgment of 12.05.2009; Pieniak v. Poland, application no. 19616/04, judgment of 24.02.2009. 275 Wiktorko v Poland, case no. 14612/02, judgment of 31.03.2009. 276 Dz.U. of 1995, no. 46, item 238, as amended. 272 273 93