Seeking Remedies for Torture Victims: A Handbook on the Individual Complaints Procedures of the UN Tready Bodies in Gunaratna v. Sri Lanka, the HRC requested the State to take interim measures to protect the alleged victim and his family after he received death threats to make him withdraw the complaint he had filed of allegations of torture in police custody.328 So far, the CAT Committee has called for the application of interim measures almost exclusively in cases concerning the implementation of the non-refoulement obligation under Article 3 of the Convention. This can be explained by the fact that the vast majority of cases brought to the attention of the CAT Committee continue to raise claims concerning the unlawfulness of a deportation or extradition order (Article 3). However, it needs to be stressed that authors (and counsels) can (and should) pursue the issuance of interim measures to avoid irreparable harm under any other situation protected by the CAT, for example, if the alleged victim is under custody and urgently needs medical treatment to recover from injuries caused by the torture and ill-treatment he or she has been subjected to. In deciding whether to request an interim measure, the relevant Committee Rapporteur will consider the imminence of the threat to the individual or group, and whether the consequences of such action would be irreparable. A consequence is considered to be irreparable where it cannot be reversed, and where there would be no remedy which could provide adequate compensation. Thus, interim measures will not be issued “where compensation would be an adequate remedy or in deportation cases where the author of the communication would be able to return should there be a favourable finding on the merits”.329 For example, in Canepa v. Canada, the author challenged his proposed deportation from Canada to Italy. He argued that the anguish he would experience in being separated from his family and from his life in Canada would violate his rights under the ICCPR, and requested that the HRC request an interim measure to prevent his deportation while his situation was considered. His application “was refused … because he had failed to establish that his deportation would bar his re-entry to Canada in the event that a violation was found”.330 328 HRC, Gunaratna v. Sri Lanka, Comm. No. 1432/2005, para.1.2 329 Harrington, J., “Punting terrorists, assassins and other undesirables: Canada, the Human Rights Committee and requests for interim measures of protection”, 48 McGill Law Journal 55 (2003), p. 62. 330 HRC, Canepa v. Canada, Comm. No. 558/1993; ibid. p. 62. 104