held that the State breached its responsibilities to protect the individuals in its jurisdiction from inhuman and degrading treatment when it failed to act appropriately in relation to the sexual and physical abuse of the four applicants when they were children. This was because the continued abuse of the children resulted from “the pattern of lack of investigation, communication and co-operation by the relevant authorities” and “proper and effective management of their responsibilities might, judged reasonably, have been expected to avoid, or at least, minimise the risk or the damage suffered.”138 Corporal punishment The term ‘corporal punishment’ broadly refers to punishment or discipline that involves inflicting physical violence and pain on a person. Corporal punishment is not specifically mentioned in international human rights instruments. However, the CRC includes the following provisions: Article 19 States Parties shall take all appropriate legislative, administrative, social and educational measures to protect the child from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s) or any other person who has the care of the child. Such protective measures should, as appropriate, include effective procedures for the establishment of social programmes to provide necessary support for the child and for those who have the care of the child, as well as for other forms of prevention and for identification, reporting, referral, investigation, treatment and follow-up of instances of child maltreatment described heretofore, and, as appropriate, for judicial involvement. Article 28 … States Parties shall take all appropriate measures to ensure that school discipline is administered in a manner consistent with the child’s human dignity and in conformity with the present Convention. 137 138 E v the United Kingdom, judgment of the ECHR, 26 November 2002. E v the United Kingdom, judgment of the ECHR, 26 November 2002 at [100]. 94