the detainee is deprived of communication with the outside world will allow the Court to conclude that he or she was subjected to ill-treatment.539 The Inter-American Commission has applied the Court’s approach,540 and has additionally established that even the reduction or limitation of visits is prohibited, as this constitutes an arbitrary form of additional punishment.541 “the act of depriving a person or persons of his or their freedom, in whatever way, perpetrated by agents of the state or by persons or groups of persons acting with the authorization, support, or acquiescence of the state, followed by an absence of information or a refusal to acknowledge that deprivation of freedom or to give information on the whereabouts of that person, thereby impeding his or her recourse to the applicable legal remedies and procedural guarantees.” Article 11 of the Convention lays out measures which must be taken to prevent enforced disappearances and incommunicado detention, providing: “Every person deprived of liberty shall be held in an officially recognized place of detention and be brought before a competent judicial authority without delay, in accordance with applicable domestic law. 3 The Inter-american Regional System The provisions of the ACHR and jurisprudence of the Inter-American Court and Commission concerning incommunicado detention and enforced disappearances are complemented by the Inter-American Convention on Forced Disappearance of Persons, Article 2 of which defines a forced disappearance as: The States Parties shall establish and maintain official up-to-date registries of their detainees and, in accordance with their domestic law, shall make them available to relatives, judges, attorneys, any other person having a legitimate interest, and other authorities.” Furthermore, Article 10 requires among other things that even in emergency situations, “the competent judicial authorities shall have free and immediate access to all detention centers and to each of their units, and to all places where there is Ecuador (1997), op. cit., §90; Berenson-Mejía v Peru (2004), op. cit., §103. Suárez-Rosero v Ecuador (1997), op. cit., §91. See also De la Cruz Flores v Peru (2004), op. cit., §130; Gómez-Paquiyauri Brothers v Peru (2004), op. cit., §108. 540 See, for example, Garces Valladares v Ecuador, IACommHR, Case 11778, Report No. 64/99, 13 April 1999; Levoyer Jiménez v Ecuador, IACommHR, Case 11992, Report No. 66/01, 14 June 2001. 541 See the Situation of Human Rights in Uruguay, Annual Report of the Inter-American Commission on Human Rights 1983-1984, OEA/Ser.L/V/II/63, doc.10, 28 September 1984. 539 119