CAT/C/21/D/101/1997 page 7 4.15. The State party concludes that, in the circumstances of the present case, the author’s return to Turkey would not have the foreseeable and necessary consequence of exposing him to a real risk of torture. An enforcement of the expulsion order against the author would therefore not constitute a violation of article 3 of the Convention. Counsel's comments 5.1. Regarding the question of admissibility, counsel points out, in her submission dated 12 May 1998, that the procedure for re-examining a case provided for in chapter 2, section 5 (b), of the Aliens Act requires that new circumstances be presented to the Aliens Appeal Board. In the present case there are no new circumstances. Therefore, all domestic remedies have been exhausted. 5.2. Counsel maintains that the Swedish Government has not evaluated the risk the author would face if he were to be expelled to Turkey, but has focused merely on his credibility. Counsel acknowledges that the author has on different occasions given the authorities an inconsistent account of his political activities and his flight; but these inconsistencies are not material and should be viewed in the light of the fact that the author suffers from PTSD. In this context counsel refers to the Committee’s jurisprudence in the cases of Pauline Muzonzo Paku Kisoki v. Sweden and Kaveh Yaragh Tala v. Sweden where it is stated that “complete accuracy is seldom to be expected by victims of torture and that such inconsistencies as may exist in the author's presentation of the facts are not material and do not raise doubts about the general veracity of the author's claims”. Counsel reiterates that the author is suffering from PTSD. She states that when asked why he had given different answers to the National Immigration Board in 1997 and during the initial investigative procedure in 1990, the author cried out that although he knew it was important to repeat what he had said almost seven years before, he simply couldn’t remember. 5.3. Concerning the inconsistencies, counsel further states that they are not of the magnitude that the State party claims. She states that the author has in fact not given two completely different versions of how the military discovered his activities, since the core elements are the same. Further, counsel draws the attention of the Committee to the fact that the question of how exactly the author's activities were discovered by the military in March 1990 is not really an issue, since by that time the author had already been harassed by the Turkish authorities for several years. 5.4. Counsel further refers to the Swedish Government's remark that no physical medical evidence had been produced to indicate that the author had been subjected to torture. She states that according to the specialists at the Center for Torture and Trauma Survivors in Stockholm it is not surprising that there are no physical traces on the author's body, since the forms of torture to which the author was subjected do not necessarily leave marks. 5.5. Counsel concludes that the author has presented sufficient evidence that he was politically active in the PKK and that he is well known to the Turkish authorities; that he has been detained, tortured and ill-treated because of his political activities; and finally that the human rights situation in