the burden and standard of proof where it is alleged that evidence was extracted under torture; and o the use of evidence obtained as a result of investigations prompted by statements extracted under torture (fruit of the poisoned tree). Develop an authoritative general comment on extraterritorial application of the Convention and clarify, among other issues, the elements of individual and state complicity. Ensure that future reviews of France, Germany and the United Kingdom include attention to counterterrorism intelligence cooperation with countries known for torture, guidelines for interrogations of detainees in third countries, and jurisprudence on the use of torture evidence in legal proceedings. o • • To the Special Rapporteur on human rights while countering terrorism and the Special Rapporteur on torture • Continue to draw attention to the issues discussed in this report and contribute to the development of clear guidelines for intelligence agencies with respect to cooperation with countries known for torture. To the UN Human Rights Committee • Ensure that future reviews of France, Germany and the United Kingdom include attention to counterterrorism intelligence cooperation with countries known for torture, guidelines for interrogations of detainees in third countries, and jurisprudence on the use of torture evidence in legal proceedings. 61 Human Rights Watch | June 2010