20 JALLOH v. GERMANY JUDGMENT health (see, mutatis mutandis, Nevmerzhitsky, cited above, §§ 94 and 97, and Schmidt, cited above). 72. Moreover, as with interventions carried out for therapeutic purposes, the manner in which a person is subjected to a forcible medical procedure in order to retrieve evidence from his body must not exceed the minimum level of severity prescribed by the Court’s case-law on Article 3 of the Convention. In particular, account has to be taken of whether the person concerned experienced serious physical pain or suffering as a result of the forcible medical intervention (see Peters v. the Netherlands, no. 21132/93, Commission decision of 6 April 1994, DR 77-B; Schmidt, cited above; and Nevmerzhitsky, cited above, §§ 94 and 97). 73. Another material consideration in such cases is whether the forcible medical procedure was ordered and administered by medical doctors and whether the person concerned was placed under constant medical supervision (see, for example, Ilijkov v. Bulgaria, no. 33977/96, Commission decision of 20 October 1997, unreported). 74. A further relevant factor is whether the forcible medical intervention resulted in any aggravation of his or her state of health and had lasting consequences for his or her health (see Ilijkov, cited above, and, mutatis mutandis, Krastanov v. Bulgaria, no. 50222/99, § 53, 30 September 2004). 2. Application of those principles to the present case 75. At the outset the Court notes that in the Government’s view the removal of the drugs from the applicant’s stomach by the administration of emetics could be considered to be required on medical grounds, as he risked death through poisoning. However, it is to be observed that the domestic courts all accepted that, when ordering the administration of emetics, the authorities had acted on the basis of Article 81a of the Code of Criminal Procedure. This provision entitles the prosecuting authorities to order a bodily intrusion to be effected by a doctor without the suspect’s consent in order to obtain evidence, provided that there is no risk of damage to the suspect’s health. However, Article 81a does not cover measures taken to avert an imminent danger to a person’s health. Furthermore, it is undisputed that the emetics were administered in the absence of any prior assessment of the dangers involved in leaving the drug bubble in the applicant’s body. The Government also stated that emetics are never administered to juvenile dealers unless they are suspected of selling drugs on a commercial basis. Juvenile dealers are, however, in no less need of medical treatment than adults. Adult dealers, for their part, run the same risks to their health as juvenile dealers when administered emetics. Consequently, the Court is not satisfied that the prosecuting authorities’ decision to order the impugned measure was based on and required by medical reasons, that is, the need to protect the applicant’s health. Instead, it was aimed at securing evidence of a drugs offence.