distress to an individual who was presumably subjected to ill-treatment in the CIA RDI programme.438 MANAGEMENT OF HUNGER STRIKES AND FORCE-FEEDING AT GUANTÁNAMO 229. Since 2002, detainees have reportedly participated in several hunger strikes to protest their treatment and detention without trial.439 During the most recent mass hunger strike, which is said to have started in February 2013,440 detainees who lived communally were all moved back to single cells. Several detainees and attorneys reported that a substantial deterioration of confinement conditions followed this move and that deliberate measures were put in place that specifically targeted the hunger strikers. Complaints have related to: noise disturbances during sleep and at prayer times; manipulation of temperature in cell blocks to produce cold; removal of basic necessities such as toothbrushes, toothpaste, soap, towels and blankets; invasive and humiliating body-cavity searches; offers to take showers or recreation in the middle of the night; the limitation of recreation to only one hour per day; and the withholding of drinkable water and medication.441 A few months after the start of the hunger strike, it was also reported that US authorities promised detainees a return to communal detention if they gave up their protest, and that the official number of hunger strikers dropped from 106 to 70 in 10 days.442 Such practices seem to constitute a system of punishment or reward implemented to break the hunger strike and discourage detainees from continuing to protest. Such a system would be unjustifiable and would violate a 438 See, for example, Senate Study on the CIA RDI Programme, Executive Summary, op. cit., note 171, pp. 75-81. See, also, the findings of the ECtHR that “CIA documents give a precise description of the treatment to which High Value Detainees were being subjected in custody as a matter of precisely applied and predictable routine, starting from their capture through rendition and reception at the black site, to their interrogations”. ECtHR, Al Nashiri v. Poland, op. cit., note 172, para. 512. 439 Widespread early hunger strikes have reportedly included one from February to May 2002, with a peak of 194 participants, and one in June-July 2005 in which approximately 200 detainees participated. “The Guantánamo Prisoner Hunger Strikes and Protests”, Center for Constitutional Rights, op. cit., note 405, pp. 7-11. 440 “IACHR, UN Working Group on arbitrary detention, UN Rapporteur on torture, UN Rapporteur on human rights and counterterrorism, and UN Rapporteur on health reiterate need to end the indefinite detention of individuals at Guantánamo Naval Base in light of current human rights crisis”, OHCHR website, op. cit., note 107. The 2013 hunger strike started following what has been described as invasive and dehumanizing cell searches. Reportedly, detainees covered the surveillance cameras and windows of their cells, and the decision was taken to move all detainees to individual cells. Participation in the hunger strike would have increased substantially at that point. See, for instance, “Hunger-Striking Detainees At Guantanamo Are Force-Fed”, transcript of an interview with Carol Rosenberg, NPR website, 2 May 2013, <http://www.npr.org/2013/05/02/180491232/hunger-strikingdetainees-at-guantanamo-are-force-fed>; “I Am Fallen into Darkness”, Amnesty International, op. cit., note 247, p. 10. 441 United States District Court for the District of Columbia, In re: Guantánamo Bay Detainee Continued Access to Counsel, Case No. 12-398, “Emergency motion concerning access to counsel”, 22 May 2013, Exhibit G, “Declaration of Anne Richardson”,<http://www.lawfareblog.com/wp-content/uploads/2013/05/secondsetoffiles.zip>; United States District Court for the District of Columbia, Suhail Abdu Anam, et al. v. Barack Obama, Case No. 04-1194, “Memorandum of law in support of emergency motion of petitioner Musa’ab Omar al Madhwani for humanitarian and life-saving relief”, 10 April 2013, <http://big.assets.huffingtonpost.com/GuantanamoWaterFiling.pdf>; “Arbitrary Detention at Guantánamo”, Center for Constitutional Rights, 11 September 2013, pp. 6-7, <http://www.ccrjustice.org/files/Guantanamo_CCR_9-1113%20%28A4%29.pdf>; Mark Townsend, “Guantánamo guards ‘forcing inmates to stay awake’”, The Guardian website, 7 July 2013, <http://www.theguardian.com/world/2013/jul/07/guantanamo-guards-inmates-stay-awake>; Moath al-Alwi, “My life at Guantanamo”, Al Jazeera website, 7 July 2013, <http://www.aljazeera.com/indepth/opinion/2013/07/201373145723725101.html>; Matt Williams, “Guantánamo hunger-strike inmates forced to drink dirty water, court hears”, The Guardian website, 15 April 2013, <http://www.theguardian.com/world/2013/apr/15/guantanamo-bay-hunger-strike-dirty-water>; ODIHR interview with Brent Rushforth, op. cit., note 207. 442 “I Am Fallen into Darkness”, Amnesty International, op. cit., note 247, p. 11. 98