Persons deprived of their liberty are recognised to deserve particular protection under the Article 3 prohibition1. The vulnerability of prisoners has been recognised both in domestic courts2 and by the European Court of Human Rights3, as well as by international human rights bodies4. Persons detained in immigration detention and in psychiatric hospitals also merit particular protection under the Article 3 prohibition: the European Court of Human Rights has recognised the increased vulnerability of detained psychiatric patients, which requires increased vigilance in reviewing compliance with the Convention, including the Article 3 prohibition
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