the involvement of State institutions at all stages.142 Although the applicant did not suffer any severe or long-lasting physical effects, the ECHR found that his punishment constituted degrading treatment. It follows from this decision that a judicial sentence involving corporal punishment will violate the prohibition on ill-treatment. • In Campbell and Cosans v United Kingdom the ECHR held that a sufficiently real and immediate threat of torture or other ill-treatment may itself constitute a breach of the provision.143 However, in this case, threatening two schoolboys with corporal punishment was not sufficiently severe to amount to torture or to inhuman treatment. In our view, international law has evolved so that there is also a general prohibition on corporal punishment against adults on the basis that it constitutes torture or cruel, inhuman or degrading treatment or punishment (see for example General Comment 20 of the HRC). Judicial sentences involving corporal punishment, regardless of whether they are permissible under domestic law, will therefore violate the prohibition on torture and cruel, inhuman or degrading treatment or punishment. Death penalty There is evolving authority for the proposition that the implementation of the death penalty per se breaches the prohibition against torture and/or cruel, inhuman or degrading treatment or punishment. It is accepted, however, that, in any event, torture can arise in the context of the death penalty at several stages, including the method of execution, procedural requirements, conditions on death row and the ‘death row phenomenon’. Method of execution: 142 143 Tyrer v the United Kingdom, judgment of the ECHR, 15 March 1978 at [33]. Campbell and Cosans v United Kingdom (1982) ECHR (Series A) No 48 at [26]. 96