Seeking Remedies for Torture Victims: A Handbook on the Individual Complaints Procedures of the UN Tready Bodies Committee concludes its considerations and examination, and the formulation and Communication of its views.335 It emphasized that this breach was “particularly inexcusable”336 given the request for interim measures. In connection with this case law, in Israil v. Kazakhstan, the HRC added: [A]part from any violation of the Covenant found against a State party in a communication, a State party commits grave breaches of its obligations under the Optional Protocol if it acts to prevent or frustrate consideration, by the Committee, of a communication alleging a violation of the Covenant, or to render examination by the Committee moot and the expression of its Views nugatory and futile.337 The HRC’s position in this regard has also been reinforced in its General Comment No. 33, which mentions that “failure to implement such interim or provisional measures is incompatible with the obligation to respect in good faith the procedure of individual communication established under the Optional Protocol”.338 The HRC has also mentioned the obligation to respect interim measures in some of its Concluding Observations.339 In these Concluding Observations, the Committee recalls that each State party has to fulfil its obligations under the Covenant and the Optional Protocol, including requests for interim measures, in accordance with the principle of pacta sunt servanda.340 The CAT Committee has taken a similar position to the HRC. In Brada v. France, the CAT Committee stated: The State party’s action in expelling the complainant in the face of the Committee’s request for interim measures nullified the effective exercise of the right to complaint conferred by article 22, and has rendered the Committee’s final decision on the merits futile and devoid of object. The Committee thus concludes that in expelling the complainant in the circumstances that it did the State party breached its obligations under article 22 of the Convention.341 In Agiza v. Sweden, the victim was deported to Egypt in breach of Article 3 of the CAT. He was deported immediately after the deportation decision was made, which denied him the ability to meaningfully appeal the decision.342 The CAT Committee also found that the swiftness of the deportation denied the complainant 335 HRC, Piandong v. The Philippines, Comm. No. 869/1999, para. 5.2. See also HRC, Israil v. Kazakhstan, Comm. No. 2024/2011, para. 7.1. 336 HRC, Piandong v. The Philippines, Comm. No. 869/1999, para. 5.2. 337 HRC, Israil v. Kazakhstan, Comm. No. 2024/2011, para. 7.2. 338 HRC, General Comment No. 33, para. 19. 339 See, e.g., Concluding Observations on Uzbekistan, (2005) UN Doc. CCPR/CO/83/UZB, para. 6; Concluding Observations on Tajikistan, (2005) UN Doc. CCPR/CO/84/TJK, para. 8; Concluding Observations on Canada, (2006) UN Doc. CCPR/C/CAN/CO/5, para. 7. 340 Article 26 of the Vienna Convention on the Law of Treaties. 341 CAT Committee, Brada v. France, Comm. No. 195/2002, para. 13.4. 342 This circumstance entailed a separate procedural breach of Article 3. 106