including the deprivation of food and drink, despite the applicant’s delicate state of health following a hunger strike.533 However, this finding would appear to be limited to the circumstances of that case. In the more recent case Rosario Congo v Ecuador, the Commission found that solitary confinement amounted to inhuman and degrading treatment.534 The Inter-american Regional System 3 3.3.5 Incommunicado detention and enforced disappearances As discussed in section 3.3.1, the prohibition of torture and ill-treatment is absolute. States must adopt measures to reinforce this prohibition, including prohibiting, in exceptional and any other circumstances, long periods of confinement without communication or legal means and remedies to assert rights.535 Facilitating communication with the outside world is one of the most effective methods of preventing and detecting torture and ill-treatment in places of detention. As the Inter-American Court stated in Suárez-Rosero v Ecuador, “isolation from the outside world produces moral and psychological suffering in any person, places him in a particularly vulnerable position, and increases the risk of aggression and arbitrary acts in prisons.”536 The Court has therefore consistently held that: “Incommunicado detention is an exceptional measure the purpose of which is to prevent any interference with the investigation of the facts. Such isolation must be limited to the period of time expressly established by law. Even in that case, the State is obliged to ensure that the detainee enjoys the minimum and non-derogable guarantees established in the Convention and, specifically, the right to question the lawfulness of the detention and the guarantee of access to effective defense during his incarceration.”537 While incommunicado detention is not absolutely prohibited by the ACHR, it may constitute cruel, inhuman or degrading treatment where it is arbitrary, prolonged, or in violation of domestic laws.538 In such cases, the mere fact that Ibid. §86. Rosario Congo v Ecuador, IACommHR, Case 11427, Report No. 63/99, 13 April 1999, §59. 535 Habeas Corpus in Emergency Situations (Articles 27(2), 25(1) and 7(6) of the American Convention on Human Rights), Advisory Opinion OC-8/87 of 30 January 1987, IACHR (Series A) No. 8, §36. 536 Suárez-Rosero v Ecuador (1997), op. cit., §90. See also Castillo Petruzzi and Others v Peru (1999), op. cit., §195; Cantoral-Benavides v Peru (2000), op. cit., §84; Bamaca-Velásquez v Guatemala (2000), op. cit., §150; Urrutia v Guatemala (2003), op. cit., §87. 537 Ibid. §51. 538 See, for example, Cantoral-Benavides v Peru (2000), op. cit., §§82–83; Bamaca-Velásquez v Guatemala (2000), op. cit., §150; Urrutia v Guatemala (2003), op. cit., §87; Suárez-Rosero v 533 534 118