- 113 safe place to LTTE members who allegedly were involved in what is considered to be one of the major assassinations committed by the LTTE. The complainant would very likely be detained and interrogated at the airport upon his return to Colombo. 2.8 Counsel further submits that there are substantial grounds for believing that the complainant would be in danger of being subjected to torture by Sri Lankan police, security forces and the LTTE if he returned to Sri Lanka. The complainant experienced torture and ill-treatment by the authorities and the LTTE before he left the country. Counsel quotes Human Rights Watch reports and reports by the United States Department of State of 1996 as evidence of a consistent pattern of gross and systematic violations of human rights in Sri Lanka. Counsel argues that under the Prevention of Terrorism Act and Emergency Regulations the police can arrest on the basis of mere suspicion, often based on the presumption of guilt arising merely from a person coming from the north or east of the country. In such an atmosphere, counsel sees every chance that the complainant, as a Tamil-speaking young man from the Eastern Province of Sri Lanka, will be harassed and mistreated by the authorities on mere suspicion. Counsel quotes from Sri Lankan newspaper headlines and articles in this regard. The complaint 3.1 Counsel submits that the evaluation of evidence in asylum procedures in Australia is deficient. Counsel argues that the Australian immigration authorities expect an applicant to give the full facts on his claim upon his arrival. Counsel submits that this is not justified, as asylum-seekers behave initially in an irrational and inadequate way, do not trust the authorities and are only ready to tell the true and complete story after having been in the country for some time. Therefore, the opinion of the Australian Government that whatever is invoked later is not trustworthy is considered absurd by counsel, as in cases such as the complainant’s new statements have to be accepted by the RRT in spite of the fact that the story was incoherent, inconsistent and contradictory in the beginning. 3.2 Counsel claims that the deportation of the complainant to Sri Lanka violated article 3 of the Convention against Torture and Other Inhuman or Degrading Treatment or Punishment. Counsel argues that there were substantial grounds for believing that the complainant would be in danger of being subjected to torture if deported. Given the absolute prohibition to expel a person where he risks being subjected to torture, counsel submits that the complainant should not have been removed. 3.3 Counsel claims that the evidence of a consistent pattern of gross and massive violations of human rights in Sri Lanka prohibits the Government of Australia from expelling the complainant.