CCPR/C/114/D/2038/2011 survived enforced disappearance. Most of the victims, once placed in secret detention, died under torture or were summarily executed. A few were lucky enough to come out of it alive, after a few days or a few weeks of detention, especially if their cases had been made public soon enough by non-governmental organizations or United Nations protection bodies like the Working Group. A few others, in some countries, would “reappear” years or even decades later, completely shattered by the experience of confinement and the total denial of their rights. 5. This type of enforced disappearance is still practised in some contexts, and the cases that the Committee has come across in Tharu et al. v. Nepal probably fit into that category. To this form of enforced disappearance, however, has been added the practice whereby a person is made to disappear for the space of a few days or for several weeks, during which time he or she is maintained in secret detention outside any legal framework and tortured, before being handed over to the police and then to the courts, often with a falsified arrest warrant in an attempt to hide the real date of arrest. The person is then charged and tried on the basis of “confessions” obtained in fact under torture during the period of disappearance. Have these practices been created in an effort to circumvent the time condition laid down in article 7 of the Rome Statute and the particularly degrading attribute of “crime against humanity”? There is no way of knowing. But that is not essentially what matters. What really matters here is the recognition that in some cases, as in the more classic cases, the person is denied the right to recognition as a person before the law from the outset of his or her deprivation of liberty. The act of causing the person to disappear and to be placed in secret detention outside any legal framework is a way of signifying to the person’s family and acquaintances that the disappeared person is no longer a person before the law, that he or she ceases to legally exist and is no longer entitled to the protection of his or her country’s laws or of international law — and that, in those conditions, the person’s torturers can dispose of him or her exactly as they please. 6. This was why the Working Group recognized, in its general comment on the right to recognition as a person before the law in the context of enforced disappearances, that enforced disappearance represented “a paradigmatic violation” of the right to be recognized as a person before the law. f Any enforced disappearance, however long it lasts, constitutes a violation of that right. It is fortunate that the Committee has amended its jurisprudence in that sense — even in a case that did not involve that type of short-term disappearance — as it can only add greater accuracy and relevance to the legal definition of the violation. has also witnessed the use of “short term disappearances”, where victims are placed in secret detention or unknown locations, outside the protection of the law, before being released weeks or months later, sometimes after having been tortured and without having been brought in front of a judge or other civil authority. This very worrisome practice, whether it is used to counter terrorism, to fight organized crime or suppress legitimate civil strife demanding democracy, freedom of expression or religion, should be considered as an enforced disappearance and as such adequately investigated, prosecuted and punished. See also, more recently, A/HRC/27/49, para. 117: During the reporting period, the Working Group observed a pattern of short-term enforced disappearances being used in a number of countries, including Bahrain and the United Arab Emirates. The Working Group expresses its deep concern at the phenomenon. It stresses that there is no time limit, no matter how short, for an enforced disappearance to occur and that accurate information on the detention of any person deprived of liberty and their place of detention shall be made promptly available to their family members. f 16 See A/HRC/19/58/Rev.1, para. 42.