– UNCAT While the CAT has found violations of the UNCAT as regards treatment which has occurred during incommunicado detention, failures to investigate allegations of ill-treatment during such detention, and an illegal expulsion which included incommunicado detention,209 it has not found a violation based only on such detention. Instead, it sees incommunicado detention as creating a situation conducive to torture.210 Thus, the Committee requests that States parties include information on incommunicado detention in their reports under Articles 2(1) and 11, which deal with measures to prevent torture.211 1 UN TREATY BODIES violation of Article 7.”206 No further ill-treatment is necessary for a finding of a violation of Article 7. In Laureano v Peru, the Committee held that “the abduction and disappearance of the victim and prevention of contact with her family and with the outside world constitute cruel and inhuman treatment, in violation of article 7.”207 Enforced disappearances often also involve a breach of the right to life, guaranteed under Article 2 ICCPR. 208 1.3.6 Relatives of victims of human rights violations The HRC considers that families of victims of human rights violations may themselves be victims of ill-treatment, particularly in cases involving enforced disappearances or execution. Given the smaller number of cases on these issues which have come before CAT, it has yet to find such a violation. However, family members of the disappeared are explicitly recognised as victims in their own right in the International Convention for the Protection of All Persons from Enforced Disappearances. – ICCPR The HRC has found that family members of disappeared persons may themselves be victims of a violation of Article 7. In Quinteros Almeida v Uruguay, the applicant was the mother of a disappeared person arrested by military personnel in the grounds of the Venezuelan Embassy in Montevideo. The Commit Mojica v Dominican Republic, HRC Communication No. 449/1991, 15 July 1994, §5.7. Laureano v Peru, HRC Communication No. 540/1993, 25 March 1996. HRC, General Comment No. 6, 1982, §4. See also, for example, Laureano v Peru (1996), ibid. §§8.3-8.4. 209 Arkauz Arana v France, CAT Communication No. 63/1997, 9 November 1999. 210 Ibid. §11.4. See also CAT, Concluding Observations on Spain, UN Doc. CAT/C/CR/29/3, 2002, §10. 211 CAT, Guidelines on the form and content of initial reports under Article 19 to be submitted by States Parties to the Convention against Torture, UN Doc. A/60/44, Annex VII. 206 207 208 45