46 United Nations Convention Against Torture and its Optional Protocol measures, such as that the use of specific measures must be weighed against the degree of anticipated danger, that the physical and psychological means of pressure must be defined and limited in advance by issuing binding directives, and that there must be strict supervision of the implementation in practice of these directives. In a second section of its report, the Landau Commission went on to detail precisely the exact forms of pressure permissible to the GSS interrogators. This section had been kept secret out of concern that, should the narrow restrictions binding the interrogators be known to the suspects undergoing questioning, the interrogation would be less effective.110 Already in its conclusions and recommendations regarding the initial report of Israel adopted in April 1994, the Committee considered the ‘moderate physical pressure’ permitted by the Landau Commission Report as a ‘lawful’ method of interrogation ‘completely unacceptable’ as it created ‘conditions leading to the risk of torture or cruel, or inhuman or degrading treatment or punishment’, and, ‘by retaining in secret the crucial standards of interrogation to be applied in any case, such secrecy being a further condition leading inevitably to some cases of ill-​treatment’.111 75  In its consideration of the Israeli interrogation practices, the Committee did not make a clear distinction between torture and other forms of ill-​treatment which might be an indication that it does not consider the severity of pain or suffering a decisive criterion distinguishing torture from inhuman treatment.112 In light of this analysis, one might conclude that the CAT Committee applies a fairly strict interpretation of both torture and other forms of ill-​treatment prohibited by Article 16 CAT, which seems similar to the approach of the European Commission in the Greek and Northern Ireland cases. Since the other definition criteria of Article 1 CAT (intention and purpose of extracting information from a detainee) were clearly met, the Committee found a violation of both Articles 1 and 16. 76 However, in Sergei Kirsanov v Russian Federation, the Committee concluded that ‘the conditions in which the complainant was detained . . . do not appear to have caused “severe pain and suffering” within the meaning of article 1, paragraph 1, of the Convention’.113 Subsequently, the Committee, without any other explanation, found cruel, inhuman or degrading treatment within the meaning of Article 16 and seems to have reached this conclusion because in its view the severity criterion was not fulfilled. 77  In its General Comment 2 on Article 2, the Committee has recognized that there may be a difference between torture and other forms of ill-​treatment in the severity of pain and suffering but also that in any case torture does ‘not require proof of impermissible purposes’.114 This formulation leaves room for interpretation but seems to indicate that the Committee considers both the severity of pain and suffering as well as the purpose, as distinguishing elements. It thereby retains the concept of differing thresholds of relative severity as between ‘torture’ and ‘cruel or inhuman treatment’, but applies the CAT Convention threshold of simple ‘severe pain and   CAT/​C/​33/​Add.2/​Rev.1, para  10.   CAT/​C/​SR.183 and 184; CAT, ‘Report of the Committee Against Torture’ (1994) UN Doc A/​49/​44, para 168. 112   CAT/​C/​SR.339, para 6. See also the similar conclusions of the UN Special Rapporteur on Torture in SRT (Rodley) ‘Question of the human rights of all persons subjected to any form of detention or imprisonment, in particular: torture and other cruel, inhuman or degrading treatment or punishment’ (1997) UN Doc E/​CN.4/​1997/​7, para  121. 113   Sergei Kirsanov v Russian Federation, No 478/​2011, UN Doc CAT/​C/​52/​D/​478/​2011, 14 May 2014, para 11.2. 114   CAT/​C/​GC/​2 (n 88) para  10. 110 111 Zach