fell squarely within the definition of torture within the UN CAT and the ECHR was interpreted accordingly. Other treatment that the European Court has found to amount to torture includes stripping someone naked and tying their arms behind their back, and then suspending them by their arms;330 rape of a detainee by an official of the state;331 subjection to electric shocks; hot and cold water treatment; blows to the head; and threats concerning the ill-treatment of the applicant’s children.332 Similarly, intimidation and threats may fall within the definition of torture.333 The UN Special Rapporteur on Torture has pointed out that threats and intimidation are often a crucial element in assessing whether a person is at risk of physical torture and other forms of ill-treatment. Strip searches may raise issues in relation to degrading treatment and they must be conducted in an appropriate manner.334 The Special Rapporteur on Torture considers that beating, kicking, punching, stripping and the forced shaving of detainees amounts to torture as it inflicts severe pain or suffering on the victims for the purpose of intimidation and/or punishment.335 Definition of inhuman The international conventions do not provide a precise definition of “inhuman” or “degrading”, as they do of torture. The CAT describes “inhuman or degrading” as “acts […] which do not amount to torture as defined in article 1, when such acts are committed by or at the instigation of or with the consent of acquiescence of a public official or other person acting in an official capacity.” In short, if treatment or punishment causes physical or mental suffering but is not severe enough to amount to torture, it will be inhuman or degrading treatment. Physical assaults that are not severe enough to constitute torture can amount to inhuman treatment. 330 The so called “Palestinian hanging” was considered to amount to torture in ECtHR, Aksoy v. Turkey, op. cit., note 220, para. 64 (“this treatment could only have been deliberately inflicted; indeed, a certain amount of preparation and exertion would have been required to carry it out. It would appear to have been administered with the aim of obtaining admissions or information from the applicant. In addition to the severe pain which it must have caused at the time, the medical evidence shows that it led to a paralysis of both arms which lasted for some time […] The Court considers that this treatment was of such a serious and cruel nature that it can only be described as torture”). 331 “While being held in detention the applicant was raped by a person whose identity has still to be determined. Rape of a detainee by an official of the state must be considered to be an especially grave and abhorrent form of ill-treatment given the ease with which the offender can exploit the vulnerability and weakened resistance of his victim. Furthermore, rape leaves deep psychological scars on the victim, which do not respond to the passage of time as quickly as other forms of physical and mental violence. The applicant also experienced the acute physical pain of forced penetration, which must have left her feeling debased and violated both physically and emotionally”, op. cit., note 30, ECtHR, Aydin v. Turkey, para. 83 and more generally 80-88. 332 ECtHR, Akkoç v. Turkey, Applications nos. 22947/93 and 22948/93, 10 October 2000, paras. 111-119. 333 UN Commission on Human Rights, Torture and other cruel, inhuman or degrading treatment or punishment, Resolution 2001/62, 25 April 2001, para. 2. 334 “Obliging the applicant to strip naked in the presence of a woman, and then touching his sexual organs and food with bare hands showed a clear lack of respect for the applicant, and diminished in effect his human dignity. It must have left him with feelings of anguish and inferiority capable of humiliating and debasing him”, ECtHR, Valašinas v. Lithuania, Application no. 44558/98, 24 July 2001, para. 117. 335 Op. cit., note 178, Situation of detainees at Guantánamo Bay, paras. 54 (shaving may be of particular relevance to prisoners of certain religions). 122 Countering Terrorism, Protecting Human Rights