54. This Committee has consistently upheld the right to compensation for individuals whose rights under Article 3 have been violated,91 as does the Human Rights Committee and European Court of Human Rights. 92 Despite this, the draft General Comment refers to compensation only in the title of the Section “Redress and compensation.” Reference to “mechanisms of financial and legal assistance” is a poor substitute for compensation, though it is required for victims to pursue compensation claims.93 55. The General Comment should make clear that victims of Article 3 violations are entitled to adequate compensation, in line with the criteria set out in General Comment 3. There are challenges for victims outside the sending State to enforce compensation awards.94 For example, the complainant in Valetov was unable to make a court application for compensation for several years after the Human Rights Committee’s decision.95 In X v Switzerland the European Court of Human Rights observed that the deadline to claim compensation in relation to expulsion and subsequent ill-treatment had expired while the Applicant was in prison in Sri Lanka.96 Rehabilitation 56. In General Comment No. 3 this Committee affirmed that “the provision of means for as full rehabilitation as possible for anyone who has suffered harm as a result of a violation of the Convention should be holistic and include medical and psychological care as well as legal and social services.”97 The standards outlined in General Comment 3 should be reflected - or cross-referenced – where relevant to this General Comment. In previous cases, the Committee has recognized that the expelling State’s obligation to provide redress where Article 3 has been violated included the requirement to “provide as full 91 CAT, Mafhoud Brada v. France, UN Doc. CAT/C/34/D/195/2002, 24 May 2005, para. 15; CAT, Boily v. Canada, UN Doc. CAT/C/47/D/327/2007, 13 January 2012, para. 15; CAT, Alexey Kalinichenko v. Morocco, UN Doc. CAT/C/47/D/428/2010, 18 January 2012, para. 17; CAT, Abdussamatov v. Kazakhstan, UN Doc. CAT/C/48/D/444/2010, 11 July 2012, para. 15; CAT, Inass Abichou v. Germany, UN Doc. CAT/C/50/D/430/2010, 16 July 2013, para. 13; CAT, Tursonov v Kazakhstan, UN Doc. CAT/C/54/D/538/2013, 3 July 2015, para. 11; CAT, X v. Kazakhstan, UN Doc. CAT/C/55/D/554/2013, 9 October 2015, para. 14; CAT, Concluding Observations: Djibouti, UN Doc. CAT/C/DJI/CO/1, 22 December 2011, para. 14. 92 HRC, Alzery v. Sweden, UN Doc. CCPR/C/88/D/1416/2005, 10 November 2006, para. 13; HRC, Valetov v. Kazakhstan, UN Doc. CCPR/C/110/D/2104/2011, 29 April 2014, para. 16; HRC, AH v. Denmark, UN Doc. CCPR/C/114/D/2370/2014, 7 September 2015, para. 10; HRC, Ali Aarrass v. Spain, UN Doc. CCPR/C/111/D/2008/2010, 30 September 2014, para. 12. See e.g., ECtHR, X v. Switzerland, App. no. 16744/14, 26 January 2017, para. 70; ECtHR, Iskandarov v. Russia, App. no. 17185/05, 23 September 2010, para. 156; ECtHR, Hirsi Jamaa v. Italy, App. No. 27765/09, 23 February 2012, para. 215; ECtHR, El Masri v. FYRoM, App. no. 39630/09, 13 December 2012, para. 270; ECtHR, Muminov v. Russia, App. no. 42502/06, 4 November 2010, para. 18. 93 CAT, General Comment No. 3, UN Doc. CAT /C/GC/3, 19 November 2012, para. 10. 94 See e.g., HRC, Ali Aarrass v. Spain, UN Doc. CCPR/C/111/D/2008/2010, 30 September 2014, para., follow up at HRC 115th, 116th, and 118th sessions; CAT, Inass Abichou v. Germany, UN Doc. CAT/C/50/D/430/2010, 16 July 2013, follow up. 95 HRC, Valetov v. Kazakhstan, UN Doc. CCPR/C/110/D/2104/2011, 29 April 2014, follow up, 113th, 115th, and 118th sessions. 96 ECtHR, X v. Switzerland, App. no. 16744/14, 26 January 2017, para., 54. See also, para. 43. 97 CAT, General Comment No. 3, UN Doc. CAT /C/GC/3, 19 November 2012, para. 11. 26 AI Index: IOR 40/6040/2017