C O M P A R AT I V E S T U D Y In Ireland, the UK government was dealing with acts of terrorism perpetrated by members of the Irish Republican Army (“IRA”) and Loyalist groups in Northern Ireland.582 The government introduced special powers of arrest and detention without trial. These powers were widely used against members of the IRA and against persons suspected of being involved with the IRA.583 The Irish government submitted an application to the Commission alleging that various interrogation practices used by the UK authorities amounted to torture and ill-treatment that violated Article 3 of the ECHR.584 The UK government did not contest the allegations regarding the breaches of Article 3 of the ECHR. However, it maintained that the use of interrogation practices belonged to the past; the techniques had been abandoned and would not be reintroduced in the future.585 The UK government argued that it had implemented various measures to prevent torture and ill-treatment and to provide reparation for their consequences.586 In assessing the evidence submitted by the applicant, the Commission referred to the Greek case and adopted the reasonable doubt standard.587 The Irish government contested the application of the reasonable doubt standard at the ECtHR. It argued that this standard was excessively rigid. The Irish government submitted that if the reasonable doubt standard were to be applied, the system of enforcement would prove ineffective. The government further argued that in cases of prima facie evidence, States that fail to assist the Court in finding the truth would not bear a risk of finding a violation of Article 3.588 The UK government requested the ECtHR to follow the standard adopted in the Greek case.589 The ECtHR reaffirmed the approach of the Commission concerning “proof beyond reasonable doubt” relying on the Greek case.590 The ECtHR stated that: [T]o assess [the] evidence, the Court adopts the standard of proof ‘beyond reasonable doubt’ but adds that such proof may follow from the coexistence of sufficiently strong, clear and concordant inferences or of similar unrebutted presumptions of fact.591 582 Ireland, paras. 4, 11-12, 16. The conflict between these two groups was representative of the antagonism between Catholics and Protestants in Northern Ireland. The IRA, predominantly Catholic, was seeking independence from the UK and the Loyalists, predominantly Protestants, opposed the idea of independence. Ireland, para. 15. 583 Ireland, paras. 38-39. 584 These interrogation practices, the so-called “five techniques,” included wall-standing, hooding, deprivation of sleep and food, and other practices. These practices were considered to amount to torture and inhuman or degrading treatment according to the Irish government. See Ireland, paras. 2, 96-104, 106-07, 161, 167, 169. 585 Ireland, paras. 153-54. 586 Ireland, paras.152-53. 587 Ireland, para. 161. 588 Ireland, para. 161. 589 Ireland, para. 160. 590 Ireland, para. 160. 591 Ireland, para. 161. 125