48 United Nations Convention Against Torture and its Optional Protocol 3.1.2.2 Meaning of ‘severe pain and suffering’ 81  As defined in the travaux préperatoires, only conduct which causes severe pain or suffering, whether physical or mental, can amount to torture. Consequently, any treatment below this threshold, will not constitute torture. In its assessment whether the severity criterion is fulfilled, the Committee usually refers to Article 1 as a whole, and states that a specific treatment will amount to severe pain or suffering, but does not go into detail, why and how it came to this conclusion.121 In Alexander Gerasimov v Kazakhstan, the complainant was inflicted several heavy blows to his kidneys and was threatened with sexual violence, before he was forced to the floor with his hands tied behind his back. Afterwards a polypropylene bag was placed over his head with which the complainant was suffocated until he bled from his nose, ears, and from the abrasions on his face, before he lost consciousness.122 The Committee clearly found that ‘this treatment can be characterized as severe pain and suffering’123 and did not add any additional reasoning or analysis. 82  The Committee also found a violation of Article 1 of the Convention in Ntahiraja v Burundi on two accounts, without specifically explaining that the inflicted treatment amounted to severe pain and suffering. The Committee concluded torture firstly, because the complainant was violently beaten during the arrest, as well as heavily abused, humiliated, and threatened with murder during the interrogation. The Committee found a violation also on a second account the complainant was subjected to humiliations and punishments, eg by having to remove all his clothes and to sleep handcuffed on a cold cement floor. Additionally, the treatment was inflicted upon the complainant in a context where he did not have access to a judge for thirty-​two days, nor to visits or the presence of a lawyer or medical care. The Committee concluded that the humiliations and extreme conditions of detention added to the abuse and the apparent lack of medical care following these abuses also amount to torture in accordance with article 1 of the Convention.124 83  The Committee has also clearly recognized rape and other forms of gender-​based violence as torture. In the case CT and KM v Sweden, the Committee found that rape committed by public officials constitutes torture, thereby acknowledging the severity of pain and suffering caused.125 84  The Committee has also found that when a complainant was brutally beaten with blows to the face and buttocks this constitutes a treatment which amounts to torture.126 Other torture methods identified for example in the inquiry procedure regarding Mexico included handcuffing behind the back, blindfolding, deprivation of sleep, food, water and using the bathroom, mock executions, electric shocks, blows to various parts of the body, above all the ears, placing of plastic bags over the head and tightened around the neck to cause a sensation of asphyxiation, and pouring of water containing irritants such as carbonic acid or chilli powder into the mouth and/​or nose while pressure is applied 121   See eg Ramiro Ramírez Martínez et al v Mexico, No 500/​2012, UN Doc CAT/​C/​55/​D/​500/​2012, 4 August 2015. 122   Gerasimov v Kazakhstan, No 433/​2010, UN Doc CAT/​C/​48/​D/​433/​2010, 24 May 2012, paras 2.3, 12.2. 123   ibid, para 12.2. 124   Saidi Ntahiraja v Burundi, No 575/​2013, UN Doc CAT/​C/​55/​D/​575/​2013, 3 August 2015, para 7.6. 125   CT and KM v Sweden, No 279/​2005, UN Doc CAT/​C/​37/​D/​279/​2005, 17 November 2006, para 7.5. 126   See eg Ali Ben Salem v Tunisia, No 269/​2005, UN Doc CAT/​C/​39/​D/​269/​2005, 7 November 2007, para 16.4; Boniface Ntikarahera v Burundi, No 503/​2012, UN Doc CAT/​C/​52/​D/​503/​2012, 12 May 2014, para 6.2. Zach