the significant health risks involved, the
National Agency takes the view that the use of
pepper spray in confined spaces is not a
proportionate measure under any circumstances
and should therefore be avoided. This is
consistent with the view of the ECHR and the
79
CPT.
79
ECHR, Tali v. Estonia, judgment of 13/02/2014,
Application no. 66393/10, margin no. 78; CPT/Inf (2008) 33,
margin no. 86
65
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