classify as a war crime, this treatment must be carried out as part of a plan or policy or as part of a large-scale commission of such crimes.129 Interrogation The prohibition against torture and cruel, inhuman or degrading treatment or punishment applies prior to, during or subsequent to interrogation. The ACJ has developed minimum standards of interrogation designed to ensure that the prohibition on torture and cruel, inhuman or degrading treatment or punishment is adhered to. We note that the (UN) Principles of Medical Ethics and Torture prohibit health personnel from applying their knowledge and skills in order to assist in the interrogation of detainees in a manner that may adversely affect their physical or mental health or condition. Gender-based violence There is an overlap between gender-based violence and gender specific forms of torture. CEDAW130 does not refer specifically to violence, abuse, torture or ill-treatment. However, the CEDAW Committee’s General Recommendation No. 19 on violence against women refers to torture in the following context:131 Gender-based violence, which impairs or nullifies the enjoyment by women of human rights and fundamental freedoms under general international law or under human rights conventions, is discrimination within the meaning of Article 1 of the Convention. These rights and freedoms include: … (a) The right not to be subject to torture or to cruel, inhuman or degrading treatment or punishment; 129 Rome Statute, Article 8(1). Adopted and opened for signature, ratification and accession by General Assembly resolution 34/180 of 18 December 1979, entry into force 3 September 1981. 131 Similar considerations would apply under CERD. 130 91