CCPR/C/119/D/2185/2012 concludes that the State party failed in its duty to protect Rajendra Dhakal’s life, in violation of article 6 (1) of the Covenant. 11.7 The Committee takes note of the authors’ allegations that the incommunicado detention since 8 January 1999 and subsequent enforced disappearance of Rajendra Dhakal amount per se to treatment contrary to article 7. The Committee recognizes the degree of suffering involved in being held indefinitely without contact with the outside world. It recalls its general comment No. 20 (1992) on the prohibition of torture or other cruel, inhuman or degrading treatment or punishment, which recommends that States parties should make provision to ban incommunicado detention. In the present case, in the absence of a satisfactory explanation from the State party, the Committee finds that the enforced disappearance of Rajendra Dhakal constitutes a violation of article 7 of the Covenant. Having reached that conclusion, the Committee will not examine the claims regarding the violation of article 10 of the Covenant on the same grounds. 11.8 The Committee notes the anguish and distress caused to the three authors by Rajendra Dhakal’s disappearance in January 1999. Despite their efforts and the Supreme Court’s decision of 1 June 2007, the authors have never received sufficient explanation concerning the circumstances surrounding his disappearance and, in case of his death, his remains have not been returned to his family. In the absence of a satisfactory explanation from the State party, the Committee considers that those facts reveal a violation of article 7 of the Covenant with respect to the authors. Having reached that conclusion, the Committee will not examine the claims regarding the violation of the third author’s rights under article 24 (1) of the Covenant. 11.9 The Committee takes note of the authors’ allegations under article 9 that Rajendra Dhakal was detained by the police without an arrest warrant. Even admitting that his arrest was made pursuant to a valid arrest warrant, such as the one issued on 7 August 1998 by Tanahun District Court, none of the procedures required by Nepalese and international law have been met. He was never brought before a judge or any other official authorized by law to exercise judicial power, and he could not institute proceedings before a court to challenge the lawfulness of his detention. In that regard, the Committee observes that the State party has not refuted the findings of the Supreme Court’s decision of 1 June 2007. In the absence of a pertinent explanation from the State party, the Committee considers that the facts described constitute a violation of article 9 of the Covenant. 11.10 With regard to the alleged violation of article 16, the Committee notes the authors’ allegations that Rajendra Dhakal was arrested by policemen; that despite the authors’ efforts, the State party has failed to provide them with sufficient information concerning his disappearance; and that despite the Supreme Court’s ruling of 1 June 2007, no effective investigation has been carried out to ascertain his fate and whereabouts, denying him the protection of the law since 8 January 1999. The Committee is of the view that the intentional removal of a person from the protection of the law constitutes a refusal of the right to recognition as a person before the law, in particular if the efforts of his or her relatives to obtain access to effective remedies have been systematically impeded. 15 The Committee, therefore, finds that the enforced disappearance of Rajendra Dhakal deprives him of the protection of the law and of his right to recognition as a person before the law, in violation of article 16 of the Covenant. 11.11 The authors invoke article 2 (3) of the Covenant, which imposes on States parties the obligation to ensure an effective remedy for all persons whose rights under the Covenant have been violated. The Committee attaches importance to the establishment by States parties of appropriate judicial and administrative mechanisms for addressing claims of rights violations. It refers to its general comment No. 31 (2004) on the nature of the general legal obligation imposed on States parties to the Covenant, which provides, inter alia, that failure by a State party to investigate allegations of violations could in and of itself give rise to a separate breach of the Covenant (para. 15). In the present case, the Committee observes that, shortly after Rajendra Dhakal’s detention, the second author approached different 15 See communications No. 2164/2012, Basnet v. Nepal, Views adopted on 12 July 2016, para. 10.9; Tharu et al. v. Nepal, para. 10.9; and Serna et al. v. Colombia, para. 9.5. 11