assurances from the Turkish authorities that Ms. Kesbir would not be tortured would be inherently unreliable.222 Turkey’s Assurances In response to the May court decision, the Dutch authorities sought and received an additional letter of guarantee from the Turkish authorities stating that: “[T]here should be no question as to Turkey’s adherence to its obligations emanating from the international instruments that she is party to on issues that the Supreme Court has expressed its sensitivity.”223 Apparently not satisfied with this response, the Dutch authorities requested an explicit confirmation that the rights deriving from Turkey’s human rights obligations be guaranteed in the specific case of Ms. Kesbir.224 In a terse reply, the Turkish authorities complained that the Dutch authorities’ request for additional guarantees specific to Ms. Kesbir were “rather redundant and unnecessary,” but that “there should not be any doubt that she will receive a fair trial under the guarantee of the ECHR and enjoy the full rights emanating from the said Convention.”225 On September 7, 2004, the Dutch Minister of Justice decided to order Kesbir’s extradition based on the assurances. Kesbir immediately appealed and requested the Dutch Minister of Justice to justify the extradition decision in light of human rights concerns, including the reliability of Turkey’s assurances against torture and unfair trial. On November 8, 2004, a Dutch court halted Kesbir’s extradition. The court concluded that, despite some reforms, Turkey continued to breach human rights, and that the Dutch authorities should not have accepted as sufficient the general assurances offered by the Turkish authorities. The Dutch government appealed, producing one additional assurance from the Turkish authorities stating that “Ms. Kesbir will be brought before the Turkish Court without delay in accordance with relevant laws and have the unimpeded right of access to her lawyers when extradited to Turkey.”226 Human Rights Watch wrote in a December 2004 letter to Piet Hein Donner, Dutch minister of justice: 222 Human Rights Watch Letter to Piet Hein Donner, May 24, 2004. 223 Letter from Embassy of Turkey to the Dutch Ministry of Foreign Affairs, Reference No. 2004/Lahey BE/7356, May 25, 2004, copy on file with Human Rights Watch. 224 Letter from Consular Affairs Department, Legal Consular Affairs Division, Ministry of Foreign Affairs of the Netherlands to the Embassy of Turkey, Reference No. CJ/CG-04/399, July 12, 2004, copy on file with Human Rights Watch. 225 Letter from Embassy of Turkey to the Dutch Ministry of Foreign Affairs, Reference No. 184, July 26, 2004, copy on file with Human Rights Watch. 226 Letter from Embassy of Turkey to the Dutch Ministry of Foreign Affairs, Reference No. 2004/Lahey BE/15949, November 18, 2004, copy on file with Human Rights Watch. HUMAN RIGHTS WATCH VOL. 17 NO. 4(D) 74