Article 3 of the European Convention on Human Rights: A Practitioner’s Handbook sufficiently strong, clear and concordant inferences or of similar unrebutted presumptions of fact. Moreover, the level of persuasion necessary for reaching a particular conclusion and, in this connection, the distribution of the burden of proof are intrinsically linked to the specificity of the facts, the nature of the allegation made and the Convention right at stake. The Court is also attentive to the seriousness that attaches to a ruling that a Contracting State has violated fundamental rights.231 This approach has been followed in several judgments. For instance, in the case of Mathew v. the Netherlands the Court added that the term “beyond reasonable doubt�� has an autonomous meaning in the context of Convention proceedings.232 However, the term remains undefined, and the Court has yet to state with precision the nature of the standard in Convention proceedings. ii) Real Risk The Court does not apply the “beyond reasonable doubt” standard in cases of expulsion and extradition. In these cases, the applicant has to prove that there are substantial grounds of a real risk of a treatment contrary to Article 3 of the Convention. For instance, in the case of Labsi v. Slovakia the Court held the following: Expulsion by a Contracting State may engage the responsibility of that State under the Convention, where substantial grounds have been shown for believing that the person concerned, if deported, faces a real risk of being subjected to treatment contrary to Article 3. In such a case, Article 3 implies an obligation not to deport the person in question to that country.233 The reason for the “real risk” threshold in cases that involve expulsion and extradition lies in the fact that the alleged ill-treatment or torture lies in the future. To require that torture or ill treatment will occur “beyond reasonable doubt” would be too high a threshold that could almost never be met. 2.1.19 Friendly Settlement a) Introduction The friendly settlement procedure under the Convention – very much like an out of court settlement in national law – affords the parties an opportunity to resolve an issue, usually on payment to the applicant by the respondent Contracting Party of a specified sum of money or on the basis of an undertaking by the respondent Contracting Party to provide an appropriate resolution of the issue, or both. The basis for friendly settlements is found in Article 39 of the Convention,234 the relevant parts of which provide as follows: 231 232 233 234 86 Nachova and Others v. Bulgaria [GC], nos. 43577/98 and 43579/98, 6 July 2005, § 147. Mathew v. the Netherlands, no. 24919/03, 29 September 2005, § 156. Labsi v. Slovakia, no. 33809/08, 15 May 2012, § 118. See also Rule 62 of the Rules of Court.