In France, judges applied legislation involving torture also concerning a case of trafficking in human beings. Case Study 3 Trafficked children, who were exploited in domestic work, explained that they were beaten with hot irons or whipped and covered with scalding water.65 Case Study 4 http://www.esclavagemoderne.org/media/ee29.pdf. 3.2 Torture Requires Infliction of Severe Pain or Suffering Severe pain or suffering can be inflicted by physical acts, but also by non-physical acts. There are two types of torture, physical and psychological. Both forms are interrelated and both, physical and mental torture, have psychological effects. Psychological or mental torture includes for example threats to kill or torture relatives, being kept in constant uncertainty in terms of space or time or simulated executions.62 The threat of torture in itself can be a form of psychological torture.63 A study on physical and psychological health consequences on sexually exploited trafficked women and girls in Europe showed that they faced different levels of physical and sexual violence as well as threats. The physical violence by traffickers, pimps, Madams, brothel and club owners, clients, and their boyfriends included being burnt with cigarettes, choked, kicked in the head and the back, and having their head slammed against floors or walls or being assaulted with guns, knives or other objects.64 Also in cases of domestic servitude, physical violence is used to coerce the victim. Report by the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment At the same time non-physical acts such as threats are used to intimidate the trafficked person. Sexually exploited women and girls for example were intimidated during their exploitation with different threats such as beatings, harm to their families, an increase of their debt and re-trafficking. Murder threats are not uncommon.66 In cases of exploitation in domestic servitude forms of coercion like food deprivation and deprivation of sleep or verbal assaults such as insults or humiliation are often used.67 Psychological torture methods are a challenge because methods such as mock executions or sleep deprivation do not lead to any scars, “which leads to their [the victims] accounts very often being brushed away as mere allegations”. 68 Often, national criminal laws contain provisions which are similar to torture but do not cover all the elements of the torture definition. Offences such as the infliction of bodily injuries are insufficient since the definition of torture does Unprotected Work, Invisible Exploitation: Trafficking for the Purpose of Domestic Servitude The UN Committee against Torture – An Assessment Stolen smiles - The physical and psychological health consequences of women and adolescents trafficked in Europe 22 . Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment