Breach of these standards may constitute a breach of the general prohibition relating to torture under international law or lead to breaches of CAT or Article 7 and/or Article 10(1) of the ICCPR. An institution’s failure to meet certain basic requirements of detention may constitute illtreatment. The following conditions have been found to violate the prohibition on degrading or inhuman treatment and, in some cases, the prohibition on torture: • prolonged incommunicado detention in an unknown location;90 • displaying a detainee to the media in a cage;91 • denial of family visits and the inability to receive and send correspondence for a year;92 • lack of bedding, sanitation, artificial light and recreational facilities, confinement for 23 hours a day, inadequate medical services and deplorable food;93 • detention for 10 years alone in a cell measuring 6 feet by 14 feet for 21½ hours a day with no recreational facilities or books;94 • prison warders assaulting a prisoner and repeatedly soaking his bedding;95 and • deprivation of food and water for several days, and denial of medical attention after illtreatment.96 88 Adopted by the First United Nations Congress on the Prevention of Crime and the Treatment of Offenders, held at Geneva in 1955, and approved by the Economic and Social Council by its resolution 663C (XXIV) of 31 July 1957 and 2076 (LXII) of 13 May 1977. 89 Adopted by UN General Assembly resolution 45/113 of 14 December 1990. 90 See for example Atachahua v Peru, Communication No 540/1993: Peru. 16/04/96. CCPR/C/56/D/540/1993 at [8.5] and N’Goya v Democratic Republic of Congo Communication No 542/1993: Democratic Republic of Congo. 16/04/9.6 CCPR/C/56/D/542/1993 at [5.5]. 91 Polay v Peru Communication No 577/1994: Peru. 09/01/98. CCPR/C/61/D/577/1994 at [8.5]. 92 Polay v Peru, Communication No 577/1994: Peru. 09/01/98. CCPR/C/61/D/577/1994 at [8.6]. 93 Deidrick v Jamaica, Communication No. 619/1995: Jamaica. 04/06/98. CCPR/C/62/D/619/1995 at [9.3]. However, in some cases similar conditions will constitute only a violation of Article 10 (see for example Taylor v Jamaica, Communication No. 705/1996: Jamaica. 04/06/98. CCPR/C/62/D/705/1996 at [7.4]). 94 Edwards v Jamaica, Communication No. 529/1993: Jamaica. 19/08/97. CCPR/C/60/D/529/1993 at [8.3]. 95 Young v Jamaica Communication No 615/1995: Jamaica. 17/12/97. CCPR/C/61/D/615/1995/Rev.1 at [5.2]. 96 Miha v Equatorial Guinea Communication No 414/1990: Equatorial Guinea. 10/08/94. CCPR/C/51/D/414/1990 at [6.4]. 80