subjected to torture or cruel, inhuman and degrading treatment, taking into account the conflict in Kashmir and the persecution they would allegedly face as a result of this conflict. The Committee declared this complaint inadmissible, having concluded that the complainant did not have locus standi to act on behalf of the alleged victims in accordance with article 22, paragraph 1, of the Convention. The text of this decision is reproduced in annex XIII, section B, to the present report. 81. Also at its forty-first session, the Committee adopted Views on complaints Nos. 257/2004 (Keremedchiev v. Bulgaria), 285/2006 (A.A. et al. v. Switzerland), 291/2006 (Saadia Ali v. Tunisia), 306/2006 (E.J. et al. v. Sweden), 316/2007 (L.J.R. v. Australia), 326/2007 (M.F. v. Sweden), 332/2007 (M.M. et al. v. Sweden). The text of these decisions is reproduced in annex XIII, section A, to the present report. 82. Complaint No. 257/2004 (Keremedchiev v. Bulgaria), concerned a Bulgarian national who alleged that police officers used disproportionate force against him and that he was unable to obtain redress within the State party. The State party in turn argued that the police officers in question had acted lawfully, within their competencies defined by the Law on the Ministry of Interior, and that their acts do not constitute “torture” within the meaning of article 1, paragraph 1, of the Convention. Upon review of the medical reports provided by the complainant, the Committee observed that he suffered multiple bruising on various external parts of his body, to the extent that the injuries inflicted caused bruising to his kidneys and blood in his urine. In addition, the forensic medical report ordered by the authorities of the State party for the purposes of the investigation, attests to the injuries described in the two earlier medical reports and gives the view that these injuries could have arisen at the time of and in the manner described by the complainant. While recognizing that pain and suffering may arise from a lawful arrest of an uncooperative and/or violent individual, the Committee considered that the use of force in such circumstances should be limited to what is necessary and proportionate. The State party argued that the force used was “necessary”, and stated that the complainant had to be handcuffed, however it did not describe the type of force used nor said whether and/or how it was proportionate, i.e. how the intensity of the force used was necessary in the particular circumstances of the case. The Committee considered the complainant’s injuries too serious to correspond to the use of proportionate force by two police officers, particularly as it would appear that the complainant was unarmed. It found on the basis of the evidence before it that the treatment of the complainant by the police officers amounted to acts of cruel, inhuman or degrading treatment or punishment, contrary to article 16 of the Convention. The Committee also concluded that the investigation into the incident in question did not meet the requirements of impartiality under article 12 of the Convention. 83. Complaints Nos. 285/2006 (A.A. et al. v. Switzerland), 306/2006 (E.J. et al. v. Sweden), 326/2007 (M.F. v. Sweden), and 332/2007 (M.M. et al. v. Sweden) concerned asylum-seekers who claimed that their expulsion, return or extradition to their countries of origin would violate article 3 of the Convention, as there they would be at risk of being subjected to torture. The Committee, after examining the claims and evidence submitted by the complainants as well as the arguments from the States parties concerned concluded that such risk had not been established. Accordingly, no breach of article 3 was found in these cases. 84. Complaint No. 291/2006 (Saadia Ali v. Tunisia), concerned a French-Tunisian national who claimed a violation of articles 1 and 2, as the State party had failed in its duty to take 135