33 Protesters at G20 in Toronto boxed in by riot police at Queen and Spadina, 17 June 2010, by Jonas Naimark is licensed under CC BY 3.0 Any additional use of force, or threats of use of force, on those already contained may amount to excessive force and could lead to panic or injuries arising out of a crush or stampede. There is some divergence as to whether human rights law and standards permit the use of containment (kettling) as a crowd-control tactic. The UN Special Rapporteur on the Rights to Freedom of Peaceful Assembly and of Association described kettling as “intrinsically detrimental to the exercise of the right to freedom of peaceful assembly, due to its indiscriminate and disproportionate nature”.44 He recommended that the practice be ended.45 44 45 UN Special Rapporteur on the Rights to Freedom of Peaceful Assembly and of Association, “Mission to the United Kingdom of Great Britain and Northern Ireland”, 17 June 2013, UN Doc. A//HRC/23/39/Add.1., para. 37, <https://www.refworld.org/docid/525fab2a4.html>. Ibid., para. 93; and “Report of the Special Rapporteur on the Rights to Freedom of Peaceful Assembly and of Association on his Follow-Up mission to the United Kingdom of Great Britain and Northern Ireland”, 8 June 2017, UN Doc. A/HRC/35/28/Add.1, para. 91, <https://digitallibrary.un.org/ record/1298881?ln=en>.