unclear whether the CAT will find any other method of execution to be acceptable in the future.162 UN TREATY BODIES 1 In addition to its findings on the death penalty as a whole, the CAT has taken a similar approach to the HRC in finding that specific characteristics or circumstances of the convicted person may render imposition of the death penalty to be cruel, inhuman or degrading in a particular case. For example, execution of the death penalty on a woman that has just given birth would probably constitute inhuman and degrading treatment.163 Like the HRC, the CAT has found violations related to conditions of detention on death row, and has recommended in its Concluding Observations in such cases that conditions be improved.164 A case specifically involving death row phenomenon has yet to come before the CAT, so it is unclear whether the CAT will follow HRC jurisprudence in this regard. 1.3.2.2 Corporal punishment The issue of corporal punishment has been considered by the HRC, CAT and, as regards minors, the Committee on the Rights of the Child (CRC). – ICCPR In its General Comment on Article 7, the HRC stated that the prohibition in Article 7 extends to “corporal punishment, including excessive chastisement ordered as punishment for a crime or as an educative or disciplinary measure.”165 The subsequent case law of the Committee has shown that any corporal punishment will be held to violate the ICCPR. In Osbourne v Jamaica the HRC stated that “Irrespective of the nature of the crime that is to be punished, however brutal it may be, it is the firm opinion of the Committee that corporal punishment constitutes cruel, inhuman and degrading treatment or punishment contrary to article 7 of the Covenant.”166 In Higginson v Jamaica, the Committee confirmed Individual Committee members have commented on other methods of execution. For example, Mr. Mavrommatis expressed serious concern that execution by hanging was not considered inhuman in Japan: CAT, Summary record of the 767th meeting, UN Doc. CAT/C/SR.767, 2007, §40. 163 Discussion of Libya, Summary record of the 381st meeting, UN Doc. CAT/C/SR.381, 1999, §38. 164 See, for example, CAT, Concluding Observations on Japan, UN Doc. CAT/C/JPN/CO/1, 2007, §19; CAT, Concluding Observations on Guyana, UN Doc. CAT/C/GUY/CO/1, 2006, §23. 165 HRC, General Comment No. 20, 1992, §5. 166 Osbourne v Jamaica (2000), op. cit., §9.1. See also Higginson v Jamaica, HRC Communication No. 792/1998, 28 March 2002, §6; Pryce v Jamaica, HRC Communication No. 793/1998, 15 March 2004, §6.2; Sooklal v Trinidad and Tobago, HRC Communication No. 928/2000, 25 162 36