EL HASKI v. BELGIUM JUDGMENT 25 Court to confirm that the alleged torture had to be established “beyond reasonable doubt”, and that, while general evidence of the human rights situation in the country from where the statement had been obtained might well be sufficient to trigger an inquiry by the domestic court into the provenance of the statement in issue, this would rarely be sufficient to establish “beyond reasonable doubt” that a particular statement had been obtained using torture: evidence of a direct causal link would in principle be necessary. They added that the standard of proof “beyond reasonable doubt” also corresponded to the requirement of Article 15 of the UN Convention against Torture, under which it had to be “established” that the statement in question had been made as a result of torture for the exclusionary rule to apply. That standard was moreover consistent with the approach taken by other courts and tribunals, in particular the United Kingdom House of Lords in A. and Others v. Secretary of State for the Home Department (no. 2). 75. The United Kingdom Government further observed that it was clear from the Court’s case-law – in particular the judgments in Jalloh v. Germany ([GC], no. 54810/00, § 105, ECHR 2006-IX) and Ashot Harutyunyan v. Armenia (no. 34334/04, 15 June 2010) – that the exclusionary rule did not apply where the domestic court was left with a doubt as to whether the statement had been obtained by torture or where it concluded that the ill-treatment did not reach the necessary threshold of severity to be classified as “torture”. It emphasised in this context that the above-mentioned Article 15 applied only in relation to torture and not to cases of other prohibited ill-treatment. In their view, in any event, the domestic courts retained in such cases some discretion as to the admissibility of and assessment of weight to be given to such a statement, to be exercised bearing in mind the special status of Article 3 and the fact that the use of a statement obtained as a result of a violation of one of the core rights guaranteed by the Convention raised serious issues as to the fairness of the proceedings. The fairness of the proceedings had then to be assessed on a case-by-case basis, considering the proceedings as a whole. 2. NGOs European Center for Constitutional and Human Rights and REDRESS 76. The third-party interveners pointed out that the “exclusionary rule”, which prohibited the admission of evidence obtained by torture or cruel, inhuman or degrading treatment or punishment, was enshrined in a number of international instruments: Article 12 of the United Nations Declaration on the Protection of All Persons from Being Subjected to Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, Article 15 of the Convention against Torture and other Cruel, Inhuman or Degrading Treatment or Punishment, Article 10 of the Inter-American Convention to Prevent and Punish Torture, the Robben Island Guidelines for the