28 United Nations Convention Against Torture and its Optional Protocol delegates felt that the concepts were too vague to be applied at the criminal law and police regulation levels. 16  Some delegates proposed replacing the term ‘to prevent’ by ‘to prohibit’ in the above proposal for the text of Article 16(1). However, this proposal was not taken up in the final text of Article 16. 17  At the same time the authors of the proposal agreed to delete the words ‘in particular’ in the French text of the proposal (although the wording of the CAT retains the words ‘en particulier’). Further, one delegate expressed a reservation with respect to Article 16(2) stating that there was no necessity for such a provision. 18  During the 1981 and 1982 Working Groups certain delegations argued for and against the retention of the bracketed Article 1(2). Those arguing in favour of retaining Article 1(2) considered it essential to affirm from the very outset that the prohibition of cruel, inhuman or degrading treatment was included within the scope of the Convention and to make it clear that torture was, in their view, at the highest end of a scale of such treatment or punishment. Such a clarification was necessary in order that the crime of torture be defined with sufficient precision for purposes of their domestic criminal law. Other delegations, pointing out that there was no universally accepted concept of cruel, inhuman or degrading treatment, felt that the reference in Article 1(2) as then worded would be far too vague for inclusion in a treaty, and that it would tend to bring imprecision to the concept of torture which had been agreed upon in Article 1(1).12 As a result of the discussion in the 1982 Working Group and the incorporation of new language in Article 16(1), the Group decided to delete Article 1(2). At the same time it was agreed that the term ‘national legislation’ in Article 1(3) be replaced with ‘national law’ in order to bring that paragraph into line with Article 16(2). 19  Debate on the scope of the proposed Article 16 and in particular its reference to Articles 3, 14, and 15 continued in the 1981 Working Group. Some delegates were of the opinion that no reference should be made to Articles 3, 14, and 15. After discussion, the Working Group decided to delete the reference to Articles 3 and 15 and to retain the reference to Article 14, between square brackets. Articles 16 (1) and (2) were adopted. 20  Discussion continued in the 1982 Working Group where the United States introduced an amendment to include either the following phrases, ‘which are not sufficient to constitute torture’ or ‘which do not amount to torture’, after the words ‘inhuman or degrading treatment or punishment’. In support of the amendment, several speakers considered it important to indicate clearly in the Convention that torture was the gravest form of cruel, inhuman or degrading treatment and that the whole range of such treatment or punishment should be covered by some articles at least of the Convention. Some other delegations felt, however, that the proposal introduced an undesirable element of vagueness into the text. One opinion was that the difference between torture, as defined or referred to in national laws and in some international decisions, and cruel, inhuman or degrading treatment was one of substance and not of degree. After some debate, it was agreed to adopt the second alternative on the understanding that no delegation maintained its objection against this formulation. 21  As regards the reference to Article 14 in Article 16(1) regarding compensation some speakers, referring to Article 11 of the 1975 Declaration against Torture, favoured a reference on the grounds that victims of cruel, inhuman or degrading treatment may have 12   Report of the Working Group of the Commission on Human Rights (1981) UN Doc E/​CN.4/​L.1576 and Report of the Working Group of the Commission on Human Rights (1982) UN Doc E/​CN.4/​1982/​L.40. Zach