– UNCAT Article 10 of the UNCAT provides: 2. Each State Party shall include this prohibition in the rules or instructions issued in regard to the duties and functions of any such person.” For medical personnel, such training should now include the Manual on Effective Investigation and Documentation of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (also known as the Istanbul Protocol).100 1 UN TREATY BODIES “1. Each State Party shall ensure that education and information regarding the prohibition against torture are fully included in the training of law enforcement personnel, civil or military, medical personnel, public officials and other persons who may be involved in the custody, interrogation or treatment of any individual subjected to any form of arrest, detention or imprisonment. Article 11 of the UNCAT requires that: “Each State Party shall keep under systematic review interrogation rules, instructions, methods and practices as well as arrangements for the custody and treatment of persons subjected to any form of arrest, detention or imprisonment in any territory under its jurisdiction, with a view to preventing any cases of torture.” In Barakat v Tunisia, the CAT considered that, in a case of torture in custody leading to death, Tunisia had failed to meet its obligations under Article 11, among others.101 The CAT considers that Article 11 requires compliance with international standards including the Standard Minimum Rules for the Treatment of Prisoners102 and the Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment.103 Furthermore, the CAT frequently includes in its Concluding Observations a recommendation that States “establish a systematic and independent system to monitor the treatment in practice of persons arrested, detained or imprisoned.”104 While the Optional Protocol to the UNCAT provides for the establishment of National Preventive Mechanisms CAT, Concluding Observations on Turkey, UN Doc. CAT/C/CR/30/5, 2003, §7(k). Barakat v Tunisia, CAT Communication No. 60/1996, 10 November 1999. 102 See, for example, CAT, Concluding Observations on Kyrgyzstan, UN Doc. A/55/44, 1999, §75(e). 103 See, for example, CAT, Concluding Observations on Monaco, UN Doc. CAT/C/CR/32/1, 2004, §5(e). 104 CAT, Concluding Observations on Brazil, UN Doc. A/56/44, 2001, §120(d). See also, for example, CAT, Concluding Observations on Moldova, UN Doc. CAT/C/CR/30/7, 2003, §6(l); 100 101 25