tims should, according to article 14 of the Convention, be afforded fair and adequate compensation.”211 Having thus applied Article 14 to a case of cruel, inhuman, or degrading treatment despite the wording of the article, there appears to be no substantial reason why the CAT should not seek to apply Article 14 to other cases of cruel, inhuman, or degrading treatment not arising from disappearances. Article 15 Each State Party shall ensure that any statement which is established to have been made as a result of torture shall not be invoked as evidence in any proceedings, except against a person accused of torture as evidence that the statement was made. Features: Evidence obtained though torture inadmissible at trial Interpretation II. INDIVIDUAL ANALYSIS OF ARTICLES 1–16 OF THE CONVENTION 2. ANALYSIS OF SUBSTANTIVE PROVISIONS States Parties are obliged to ensure that any statement which is established to have been made as a result of torture shall not be invoked as evidence in any proceedings. This also indirectly gives the provision a preventive effect: Declaring that such statements are worthless removes an important motive for the use of torture.212 56 The rule that evidence of this kind cannot be accepted does not apply if the statement is invoked against the alleged torturer in order to prove that the statement was made. Members of the CAT have pointed out to States Parties that a range of supplementary measures must be taken in order to implement Article 15 effectively. For example, Committee members have been critical of judicial procedures based solely or principally on the basis of confessions of witnesses and suspects. Such procedures invite the extortion of crucial statements by force.213 The right of a person not to make statements against him- or herself must be guaranteed (non self-incrimination). Furthermore, he or she must be informed of this right.214 The problem of evidence of torture also arises in connection with Article 15. Committee members have suggested that it would be “more in keeping with the spirit of the Convention” to place on the prosecuting authority the burden of proving that a statement has not been made under duress. This could, for example, be achieved by means of a medical investigation before and after the interrogation.215 Article 15 applies only to statements made under torture and not to statements made under cruel, inhuman, or degrading treatment. However, the CAT has

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