IV. KEY DEVELOPMENTS IN THE WORK OF THE UN COMMITTEE AGAINST TORTURE IN ADDRESSING THE USE OF FORCE 38. Over the years, the Committee has dealt with cases and patterns of extra-custodial use of force in the framework of the individual communications procedure under article 22 of the Convention. Its first landmark case in this regard was Dzemajl et al. v. Yugoslavia85, where the Committee found that, in the framework of an arson attack and eviction, the burning and destruction of houses by civilians with the acquiescence of the police constituted acts of cruel, inhuman or degrading treatment or punishment, under the terms of Article 16 of the Convention alone86, and that the nature of these acts is further aggravated by the fact that the acts were committed with a significant level of racial motivation. In Sonko v. Spain87 the Committee considered that the physical and mental suffering prior to the death of a migrant, who drowned after having been thrown into the sea by the Spanish Civil Guard, exacerbated by his particular vulnerability as a migrant, amounted to cruel, inhuman or degrading treatment or punishment.88 In its concluding observations, the Committee regularly urges States under its review 85. UN Committee Against Torture, Comm. No. 161/2000. 86. See also: UN Committee against Torture, Osmani v. Serbia, Comm. No. 261/2005. 87. UN Committee against Torture, Comm. No. 368/2008. 88. W  orld Organisation Against Torture, Concept Note: Thematic briefing on extra-custodial use of force amounting to torture and other ill-treatment, January 2020. 14