other systems, a finding of torture will require ‘serious’ suffering. Furthermore, such a finding will require evidence of specific instances of physical and mental abuse; allegations phrased in general terms will not suffice.563 The African Regional System 4 128 Articles 60 and 61 of the ACHPR provide that, in interpreting the provisions of the Charter, the Commission is to draw inspiration from other sources of international law, including UN treaties and customary international law. Thus, the Commission has on occasion adopted the definition of torture contained in the UNCAT,564 and, in Democratic Republic of Congo v Burundi, Rwanda and Uganda, considered the provisions against torture contained in international humanitarian law.565 While the definition of torture has not yet been discussed in any depth by the Commission, its recent findings have been more rigorously substantiated than in the past. This development and the establishment of the African Court raise expectations that the definition of torture under the African Charter will be analysed in more depth in the future. 4.1.3 Cruel, inhuman or degrading punishment and treatment In Huri-Laws v Nigeria, the African Commission adopted the reasoning of the European Court to find that, to qualify as cruel, inhuman or degrading, treatment must reach a ‘minimum level of severity,’ the assessment of which depends on all the circumstances of the case, such as the duration of the treatment, its physical or mental effects and, in some cases, the sex, age and state of health of the victim.566 However, once this minimum standard has been met, the concept of cruel, inhuman or degrading punishment or treatment should which cause serious physical or psychological suffering, but which humiliate or force the individual against his will or conscience.”: Doebbler v Sudan, AfrCommHPR, Communication No. 236/2000, 33rd session, 15-29 May 2003, §36. This statement may suggest that the gravity of the suffering will not be a deciding factor in distinguishing between torture and other forms of ill-treatment. 563 Ouko v Kenya, AfrCommHPR, Communication No. 232/1999, 28th session, 23 October 6 November 2000, §26. 564 See, for example, Zimbabwe Human Rights NGO Forum v Zimbabwe, AfrCommHPR, Communication No. 245/2002, 39th session, 11–15 May 2006, §180. 565 Democratic Republic of Congo v Burundi, Rwanda and Uganda, Communication No. 227/1999, 33rd session, 15–29 May 2003, §70. 566 Huri-Laws v Nigeria, AfrCommHPR, Communication No. 225/1998, 28th session, 23 October–6 November 2000, §41, quoting the ECHR case Ireland v UK (1978), op. cit.