sign a statement absolving the police of any wrongdoing. According to counsel, these acts constitute "slow, methodical mental torture" for the author, and there is no need to wait for evidence of physical torture. 14.3 It is also disputed by counsel that the actions of the Indian Central Bureau of Investigation on his return to India do not constitute "mental torture". It is argued that the State party has to consider these actions together with the other difficulties faced by the author and his family since his arrival and the general human rights situation in India. Secondly, it is inappropriate that the State party uses ex post facto elements, i.e. that the author has not been tortured since his return to India, to justify its decision to expel the author. Counsel contends that the author is currently a victim of torture, but that even if that were not the case, the Committee should determine if the author is and was at the moment of deportation from Canada, at substantial risk of torture. 14.4 With regard to personal risks, counsel argues that the author has provided enough evidence in his letter and his niece's affidavit that he has been at substantial risk of torture since he arrived in India and that the Indian authorities maintain a high level of interest in him. Along these lines, it is reaffirmed that the deportation of the author is a disguised extradition even though there were no elements for requesting a formal extradition. 14.5 Counsel draws the attention of the Committee to additional sources that dispute the State party's assertion that the human rights situation in Punjab has improved.i Counsel submits that the sources confirm that the situation of human rights workers deteriorated at the end of 1998. Counsel also refers to information indicating that persons who have presented complaints before the People's Commission have been visited by the police and threatened with elimination or arrest on false charges. 14.6 Counsel argues that the State party has not been consistent in its risk assessment. While it is currently portraying the author as a person of no interest to the Indian authorities, it has previously qualified him as a high-profile militant, including pointing to his links with the Dal Khalsa, a known pro-Khalistan organization, the fact that he had intimated to the immigration authorities that he could "crush anyone with his thumb", as well as evidence of him having given pro-Khalistan, anti-Indian government statements. In this sense, the argument of the State party that the author is not a high-profile militant is, according to counsel, fallacious. Counsel further presents additional information in order to demonstrate that the author is indeed a "high-profile militant": a comment made by the British Broadcasting Corporation in May 1982 on the Dal Khalsa, characterizing it as an anti-national, secessionist, extremist organization; and an article from The News International of October 1994 on the author himself, qualifying him clearly as a militant. Counsel finally refers to information contained in the Canadian Government own file, relating to the removal of the author from Canada ("section 27 report"), dated 30 November 1995, indicating that the author "is a member of the Dal Khalsa, a known terrorist organization". Counsel emphasizes the present tense used in the sentence to demonstrate that neither the existence of the Dal Khalsa nor the affiliation of the author to the latter belongs to the past. According to counsel, these elements are a clear indication that the State party was indeed considering the author as a high-profile militant and therefore knew of the risk run by the author if he returned to India. Issues and proceedings before the Committee 15.1 The Committee must decide, pursuant to article 3, paragraph 1, of the Convention, whether there are substantial grounds for believing that the author would be in danger of being subjected to torture upon return to India. In reaching this decision, the Committee must take into account all relevant considerations, pursuant i Documents IND30759.EX and IND26992.E of the Research Directorate of the Immigration and Refugee Board in Ottawa. 107