In recognition of the seriousness of an allegation of a violation of the Article 3 prohibition1, the European Court of Human Rights applies a high standard of proof, ostensibly requiring allegations to be proved beyond reasonable doubt2. However, the Court has confirmed that in applying this standard it is not borrowing the approach of national legal systems3, and it is willing to find such proof from the coexistence of sufficiently strong, clear and concordant inferences or of similar unrebutted presumptions of fact
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