CCPR/C/112/D/2031/2011 8.4 In the instant case, the State party indicates that it has conducted an effective investigation of the incident allegedly leading to the death of Mr. Bhandari, after his detention by the security forces. However, the Committee considers that the State party has not sufficiently explained the specific circumstances of his detention and alleged death, nor has it produced sufficient evidence to indicate that it has fulfilled its obligation to protect his life. Accordingly, the Committee concludes that the State party has failed in its duty to protect the life of Mr. Bhandari, in violation of article 6 of the Covenant. 8.5 The Committee takes note of the author’s allegations under article 7 that his father was severely ill-treated by the authorities at the moment of his arrest and while in detention; that he was held without contact with the outside world; that his enforced disappearance amounts per se to a treatment contrary to article 7 of the Covenant; and that the State party has failed to carry out a prompt and effective investigation. The Committee recognizes the degree of suffering involved in being held indefinitely without contact with the outside world. It recalls its general comment No. 20 (1992) on the prohibition of torture, or other cruel, inhuman or degrading treatment or punishment, in which it recommends that States parties should make provision to ban incommunicado detention. In the present case, in the absence of a satisfactory explanation from the State party, the Committee finds that the acts of torture, to which the author’s father was subjected, and his incommunicado detention constitute a violation of article 7 of the Covenant. 8.6 The Committee also takes note of the anguish and stress caused to the author by the disappearance of his father. In particular, the author and his family have never received an adequate explanation concerning the circumstances surrounding the alleged death of his father, nor have they received his body remains. In the absence of a satisfactory explanation from the State party, the Committee considers that the facts reveal a violation of article 7 of the Covenant, with respect to the author. 8.7 The Committee takes note of the author’s allegations under article 9 that his father was detained; that he was never brought before a judge or any other official authorized by law to exercise judicial power; nor could he take proceedings before a court to challenge the lawfulness of his detention. In the absence of a response from the State party in this regard, the Committee considers that the detention of the author’s father constitutes a violation of his right under article 9 of the Covenant. 8.8 With regard to the alleged violation of article 16, the Committee reiterates its established jurisprudence, according to which the intentional removal of a person from the protection of the law for a prolonged period of time may constitute a refusal to recognize that person as a person before the law, if the victim was in the hands of the State authorities when last seen, and if the efforts of his or her relatives to obtain access to potentially effective remedies, including judicial remedies (art. 2, para. 3, of the Covenant), have been systematically impeded.8 In the present case, the Committee notes that shortly after the arrest of the author’s father, the authorities provided the author and his mother with contradictory information about his arrest. Later, they failed to provide sufficient information concerning the fate or whereabouts of Mr. Bhandari, despite many requests. Accordingly, the Committee concludes that the enforced disappearance of the author’s father since 31 December 2001 has denied him the protection of the law and deprived him of his right to recognition as person before the law, in violation of article 16 of the Covenant. 8.9 The author invokes article 2, paragraph 3, of the Covenant, which imposes on States parties the obligation to ensure an effective remedy for all persons whose rights under the 8 12 See communication No. 1905/2009, Khirani v. Algeria, Views adopted on 26 March 2012, para. 7.9.