Examples of treatment which were found not to be sufficiently severe to constitute 'inhuman' or 'degrading' treatment for the purposes of the Article 3 prohibition1 include: compulsory strip searches on visiting a prison2; handcuffing a prisoner whilst he received chemotherapy treatment3; moving elderly residents suffering from senile dementia from their nursing home4; and leaving a severely disabled woman in completely inadequate accommodation for over two years5. In light of the nature of the European Convention on Human Rights as a 'living instrument', treatment that has previously been held not to reach the threshold of severity required to constitute torture
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