circumstances of the case, such as the duration of the treatment, its physical or mental effects and, in some cases, the sex, age and state of health of the victim, etc.60 195. Furthermore, in the combined Cases of Denmark v. Greece,61 Norway v. Greece,62 Sweden v. Greece,63 and Netherlands v. Greece,64 popularly referred to as the Greek Case, the European Commission held that …” AC HP R The notion of inhuman treatment covers at least such treatment as deliberately causes severe suffering, mental or physical which in the particular situation, is unjustifiable…”65 In the same case, the European Commission also considered that, for an act to be degrading there must be some form of „gross humiliation.‟66 196. Having discussed the principle of inhuman and degrading treatment and indignity, the African Commission will rely on the criterion provided by its jurisprudence that: “Acts of inhuman and degrading treatment “Not only cause serious physical or psychological suffering, but also humiliate the individual…’ and ‘Can be interpreted to extend to the widest possible protection against abuses, whether physical or mental.‟ 60 Ireland v UK (1978) ECHR (Series A) para 162. 61 Denmark vs. Greece. 62 Norway vs. Greece. 63 Sweden vs. Greece. 64 Netherlands vs. Greece. 65 The Greek Case (1969) Yearbook: Eur.Conv. on HR 12 page 186. 66 Ibid 56