not require any bodily injuries. It is therefore unacceptable that torture is reduced to the infliction of injuries.69 The situation concerning trafficking in human beings is similar. In practice, cases of trafficking in human beings are difficult to prove without any physical violence.70 In cases of forced labour, subtle means of coercion are used. In domestic servitude, verbal, emotional and subtle psychological violence are characteristic, which cause serious long-term consequences for the person’s well-being.71 Traffickers create an unpredictable and unsafe atmosphere which is a tactic also employed by perpetrators of torture aimed at destabilizing their victims and creating extreme uncertainty about the future.72 In a study on physical and psychological health consequences on sexually exploited trafficked women and girls in Europe, 37 per cent of the women reported that their family members were threatened in case the victim would not act upon the trafficker’s will. This threat could be assimilated to torture. When the trafficker threatens to harm the family of the victim if the victim tries to resist, the victim of trafficking in human beings has to choose between his/her own safety and the safety of the family. This situation is called ‘impossible choice’ in the literature on psychological torture. Regardless of the actions she or he chooses, something aversive will happen to the victim and/or another person. In this situation the person has no capacity of self-determination and is left in a State of ‘mental defeat’. In case of trafficked women it is shown that threats against children were especially effective. 73 As in torture or CIDT, the physical and non-physical acts of the exploiters have an impact on the well-being of the trafficked person. It has been shown that victims of trafficking in human beings suffer harms similar to that of victims of torture. 74 A study on trafficked women and girls in the UK showed that 56 per cent of all interviewed women and girls had symptom levels suggestive of post-traumatic stress ., disorder (PTSD), which comes near levels identified in torture victims.75 The pain inflicted on victims of trafficking, therefore, often reaches the threshold of ‘severe’ as required by the definition of torture in Art. 1 UNCAT. The experience of the Helen Bamber Foundation concerning physical and psychological health consequences related to trafficking in human beings is thoroughly discussed in part two of the Occasional Paper. 3.3 The Torturer Has to Act Intentionally for Achieving a Specific Purpose The following section explores whether the torture-requirement of intentionally inflicting severe pain or suffering on a person for achieving a specific purpose is fulfilled within the context of trafficking in human beings. As shown above, the act of torture must be conducted intentionally. The intent of the perpetrator aims at inflicting severe pain or suffering and at achieving a specific purpose.76 The Palermo Protocol requires that countries criminalize trafficking in human beings only when conducted intentionally.77 The required intent within trafficking in human beings is to exploit. Therefore trafficking in human beings is also referred to as a crime of specific or special intent (dolus specialis). The special intent is defined as the purpose aimed at by the perpetrator when committing the material acts of the offence.78 The purpose of the crime of trafficking in human beings is the exploitation, which includes for instance the exploitation of the prostitution of others or forced labour. As a conclusion, both acts, trafficking in human beings and torture, have to be conducted intentionally. The torturer acts to achieve a specific purpose by inflicting severe pain or suffering. The trafficker intends to exploit a person by using several means, such as inflicting severe pain or suffering. Therefore, the primary purpose of trafficking in human beings, i.e., exploitation, is different from the purpose of torture, which is to achieve a specific purpose such as punishment, coercion or obtaining information. Nevertheless, the following paragraphs will show that the purposes of trafficking in human beings and torture are inThe United Nations Convention against Torture: A Commentary < > Anti-human trafficking manual for criminal justice practitioners mens rea Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, , The International Law of Human Trafficking 23