CAT/C/39/2 page 53 Committee considers torture is practised systematically when it is apparent that the torture cases reported have not occurred fortuitously in a particular place or at a particular time, but are seen to be habitual, widespread and deliberate in at least a considerable part of the territory of the country in question. Torture may in fact be of a systematic character without resulting from the direct intention of a Government. It may be the consequence of factors which the Government has difficulty in controlling, and its existence may indicate a discrepancy between policy as determined by the central Government and its implementation by the local administration. Inadequate legislation which in practice allows room for the use of torture may also add to the systematic nature of this practice”. 226. The Brazilian Government notes the Committee’s conclusion that the practice of torture could be systematic in the country. It expresses its appreciation for the statement by CAT that “the government of Brazil, fully cooperated with the Committee’s visit, constantly expressed its awareness and concern with the seriousness of the existing problems, as well as its political will to improve.” The Brazilian Government notes, in this connection, that the Committee Against Torture usually considers torture to be systematic when it is apparent that the torture cases reported have not occurred fortuitously in a particular place or at a particular time, but are seen to be habitual, widespread and deliberate in at least a considerable part of the territory of the country in question. Torture may in fact be of a systematic character without resulting from the direct intention of a Government. It may be the consequence of factors which the Government has difficulty in controlling, and its existence may indicate a discrepancy between policy as determined by the central Government and its implementation by the local administration. Inadequate legislation which in practice allows room for the use of torture may also add to the systematic nature of this practice” (emphases added). 227. As will be clearly shown further on, Brazil is already complying or considering compliance with the recommendations contained in the Report of the Committee’s investigation under article 20. Many of the measures responding to CAT’s recommendations were already being taken on the initiative of the Brazilian governmental authorities. The Brazilian Government believes that the Committee’s recommendations are significantly useful for the prevention and the struggle against torture and other cruel, inhuman or degrading treatment and punishment in any circumstances and hopes to deepen and expand its dialogue with the Committee on that account. 228. However, some points should be made regarding the conclusions of the Committee in its investigation under article 20 of the Convention. IV. SYSTEMATIC PRACTICE OF TORTURE IN INTERNATIONAL LAW 229. Brazil recalls that the Convention Against Torture mentions the systematic practice of torture in its article 20, where it provides that “If the Committee receives reliable information which appears to it to contain well-founded indications that torture is being systematically practised in the territory of a State Party, the Committee shall invite that State Party to co-operate in the examination of the information and to this end to submit observations with regard to the information concerned.” There is no indication in the text of the Convention that States Parties have intended to attach special meaning to the concept of systematic practice of torture as provided in the Convention.