231. Treatment insufficiently serious to be categorised as 'inhuman' or 'degrading'.

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