We suggest that 53 (h) and (i) are merged and the following wording is considered: “Whether the complainant has a history of PTSD or other similar symptoms that may result in their inability to disclose all relevant details of their case or cause the person to present incomplete or inconsistent accounts.” v) Paragraphs 50, 51 and 52: internal flight/relocation alternative 92. We consider that paragraphs 50-52 provide critical guidance on the approach that the Committee takes to the question of internal flight alternative. This is another instance where the Committee’s guidance is clearly applicable and relevant beyond individual communications under Article 22; the Committee authoritatively and helpfully addresses a question pertaining to States parties’ effective implementation of their non-refoulement obligations under the Convention as a whole (see also our comment at the beginning of this section). We note that the explanation in paragraph 51 of internal flight alternative, namely, “the deportation of a person or a victim of torture to an area of a State where he/she would not be exposed to torture unlike in other areas of the same State” is unwittingly too narrow since in many instances the actual place where individuals are transferred may well be the same place from which they have fled -- and where they would face a real risk -- but they are expected to safely travel to, access, and establish themselves in another area, constituting a viable internal flight alternative. We also note that often the term “internal relocation alternative” is used instead of internal flight alternative. Further, there are criteria developed under international refugee law, including with respect to safety en route, actual accessibility of the area, and reasonableness in terms of expecting the individual concerned to actually reach and stay in the said area. In practice this means that if the individual concerned would in fact be compelled to return to the site where there is a real risk of illtreatment or to another part of the country where serious harm may be a possibility, then the internal flight/relocation alternative is not viable because it would result in constructive refoulement. If the individual cannot in practice reach the proposed site of relocation then internal flight will not be a reasonable option. This would include: cases where the person was being transferred to or through the place where they have a well-founded fear of persecution; logistical or safety impediments; travelling through minefields or risking attack or banditry; extortion; etc. Thus, some critical questions concern the following: is the area of relocation practically, safely and legally accessible to the individual? Does the risk emanate from State or non-State actors? Can the individual lead a relatively normal life without facing undue hardship in the alternative location concerned? States parties should take those criteria into account when ascertaining the viability of a potential internal flight alternative. We therefore recommend the following textual revisions. Recommended textual changes: Paragraph 50 Paragraph 50: replace “expelled, returned or extradited” with “involuntarily transferred” Paragraph 51 51. The Committee considers that the so called “internal flight alternative” (also referred to as “internal relocation alternative”) i.e. the deportation of a person or a victim of torture to an area of a State where he/she would not be exposed to torture unlike in other areas of the same State requires consideration of at least the following questions in order to ascertain whether the individuals concerned would be able to avail themselves of a viable internal flight/relocation alternative: is the area of relocation practically, safely 40 AI Index: IOR 40/6040/2017