• In Chitat v Canada144 the HRC reiterated General Comment 20(44) which stated that the execution of a sentence of death must be carried out in such a way as to cause the least possible physical and mental suffering. In that case, the HRC stated that execution by gas asphyxiation constitutes cruel and inhuman treatment.145 Procedural requirements: • Detention on death row will per se constitute ill-treatment if the individual was sentenced to death in violation of one of the principles set out in Article 6.146 • Prolonged delays in the execution of a sentence of death of will not constitute torture or other ill-treatment unless there are other “compelling circumstances”.147 • A 20-hour delay between a stay of execution and removal from a death cell constitutes cruel and inhuman treatment.148 • Eight hours’ notice of execution when the execution can only take place at least one year after domestic remedies have been exhausted does not constitute torture or ill-treatment. 149 Conditions on death row: • The general principles applying to detention apply equally to death row inmates. • The HRC found that a death row detainee was subjected to degrading treatment when he was assaulted by soldiers and warders, who beat him, pushed him with a bayonet, emptied a urine bucket over his head, threw his food and water on the floor and his mattress out of the cell.150 144 Chitat v Canada, Communication No. 469/1991: Canada. 07/01/94. CCPR/C/49/D/469/1991. Chitat v Canada, Communication No. 469/1991: Canada. 07/01/94. CCPR/C/49/D/469/1991 at [16.4]. 146 See for example Clive Johnson v Jamaica, Communication No. 592/1994: Jamaica. 25/11/98. CCPR/C/64/D/592/1994 at [10.4]. The ECHR has reached the same conclusion in relation the European Convention, see Öcalan v Turkey, judgment of the ECHR, 12 March 2003 at [211]-[213]. 147 Howell v Jamaica, Communication No. 798/1998: Jamaica. 07/11/2003. CCPR/C/79/D/798/1998 at [6.3]. 148 Pratt and Morgan v Jamaica, Communication No. 210/1986: Jamaica. 07/04/89. CCPR/C/35/D/210/1987 at [13.7]. 149 Rolando v Philippines, Communication No. 1110/2002: Philippines. 08/12/2004. CCPR/C/82/D/1110/2002 at [5.4]. 150 Francis v Jamaica Communication No. 320/1988: Jamaica. 12/05/93. CCPR/C/47/D/320/1988 at [12.4]. 145 97