Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook the Court to take into account the general human rights situation in a Contracting Party when examining allegations of ill-treatment against that Party. For example, in its judgment in the case of Elçi and Others v. Turkey,175 the Court relied on the CPT’s reports on Turkey when examining the testimony of the Government’s witnesses during the fact-finding hearing. The Court observed the following: In its second public statement, issued on 6 December 1996, the CPT noted that some progress had been made over the intervening four years. However, its findings after its visit in 1994 demonstrated that torture and other forms of ill-treatment were still important characteristics of police custody. In the course of visits in 1996, CPT delegations once again found clear evidence of the practice of torture and other forms of severe ill-treatment by the police. It referred to its most recent visit in September 1996 to police establishments. It noted the cases of seven persons who had been very recently detained at the headquarters of the anti-terrorism branch of the Istanbul Security Directorate and which ranked among the most flagrant examples of torture encountered by CPT delegations in Turkey. It concluded that resort to torture and other forms of severe ill-treatment remained a common occurrence in police establishments in Turkey.176 In reference to this information, the Court stated that the Government witnesses before the Commission Delegates had “constantly denied the applicants’ allegations, but in such a strident manner as to cast doubt on their testimony in the light of the accepted background knowledge for the period”.177 Similarly, in its judgment in the case of Khashiyev and Akayeva v. Russia178 the Court, in concluding that the applicants’ version of the events was accurate, consulted reports prepared by human rights groups and documents prepared by international organisations that supported their version of events. Furthermore, in expulsion and extradition cases the Court may consult the Guidelines, Position Papers, and Country Reports published by the United Nations High Commissioner for Refugees (UNHCR).179 The Court also has regard to information and reports compiled by non-governmental organisations. For example, in the case of Kalantari v. Germany180 the Court examined evidence submitted to it by the World Organisation Against Torture (OMCT) showing that the applicant would be at risk of persecution if expelled to Iran. In Said v. the Netherlands,181 the Court concluded that the expulsion of the applicant to Eritrea would expose him to a real risk of being subjected to treatment contrary to Article 3 of the Convention relying 175 176 177 178 179 180 181 74 Elçi and Others v. Turkey, nos. 23145/93 and 25091/94, 13 November 2003. Ibid., § 599. Ibid., § 643. Khashiyev and Akayeva v. Russia, nos. 57942/00 and 57945/00, 24 February 2005, § 144. See e.g. S.A. v. Sweden, no. 66523/10, 27 June 2013, §§ 21–22 and 44. Kalantari v. Germany, no. 51342/99, 11 October 2001, §§ 35–36. Said v. the Netherlands, no. 2345/02, 5 July 2005, §§ 31–35.