40 United Nations Convention Against Torture and its Optional Protocol without prejudice to any international instrument or national legislation which does or may establish wider prohibitions.’75 57  The revised Swedish text of Article 1(3) which read ‘. . .  this Article is without prejudice to any international instrument or national legislation which does or may contain provisions of wider application relating to the subject matter of this Convention’ was adopted by consensus and later considered by the 1981 Working Group where the wording ‘national legislation’ was changed to ‘national law’ to make it consistent with Article 16(2). 58  However, as adopted by the Commission during its thirty-​seventh session in 1981, Article 1(2) read: . . . this Article is without prejudice to any international instrument or national law which does or may contain provisions of wider application. 59  There was no further debate on the paragraph at the thirty-​eighth Working Group session as it appears in the annex and contains ‘national legislation’ instead of ‘national law’. Boulesbaa has suggested that this may have been a mistake as it appears there had been a deliberate attempt to bring the paragraph into line with Article 16(2). 2.3 Reservations, Declarations, and Understandings 60 Some Governments made reservations relating to the definition of torture in Article 1.76 Botswana considered itself bound by Article 1 only to the extent that ‘torture’ means the ‘torture and inhuman or degrading punishment or other treatment prohibited by Section 7 of the Constitution of the Republic of Botswana’. A  similar reservation, limiting the Convention’s definition of torture to the definition enshrined in national legislation, was made by Fiji and Thailand.77 The Lao People’s Democratic Republic noted that the term ‘torture’, as in Article 1, ‘means torture as defined in both national law and international law.’78 Qatar even made a reservation aimed at ruling out ‘any interpretation of the provisions of the Convention that is incompatible with the precepts of Islamic law and the Islamic religion’—​a very general reservation, which Qatar partly withdrew, however ‘keeping in effect a limited general reservation within the framework of Articles 1 and 16 of the Convention’.79 The United Arab Emirates issued a controversial declaration regarding its understanding of lawful sanctions, which was strongly rejected by many European States.80 61 The United States ratified the CAT only subject to a number of ‘understandings’ as previously advised by the Senate.81 A considerable number of these ‘understandings’, some of which go beyond a mere declaration of interpretation and, in fact, amount to a 75   CHR/​XXXV/​Items 10 and 11/​WP.2, cited in E/​CN.4/​L.1470 (n 7) para 16 and Burgers and Danelius (n 32) 43. 76   For a list of declarations and reservations see below Appendices A3 and A4. 77  Reservation upon ratification by Fiji (14 March 2016); Declaration upon accession by Thailand (2 October 2007). 78   Declaration upon ratification by Lao People’s Democratic Republic (26 September 2012). 79   Qatar partially withdrew its general reservation on 14 March 2000. 80   Declaration upon accession (19 July 2012). This declaration is discussed in detail below in sub-​section 3.3 below. Austria, Belgium, Czech Republic, Finland, Ireland, Netherlands, Norway, Poland, Portugal, Romania, Sweden, and Switzerland objected to this declaration. 81   See below Appendix A4 Zach