In Dougoz v Greece the ECHR emphasised that the “cumulative effects” of the conditions of detention, as well as of specific allegations, must be taken into account when considering whether the conditions of detention constituted ill-treatment.97 The ECHR held that the conditions, in particular the serious overcrowding and absence of sleeping facilities, combined with the length of the period during which Dougoz was detained (17 months), amounted to degrading treatment. The HRC has also identified certain conditions that may violate Article 7 and/or Article 10 of the ICCPR. Some examples include: • failure to segregate pre-trial detainees from convicted prisoners;98 • lack of medical and dental care, burning of detainee’s personal belongings;99 • sharing of mattresses in detention and denial of natural light for 23 hours a day;100 • failure to provide medical treatment to death row inmates with skin condition;101 and • deprivation, temporarily or permanently, of the use of any of the detainee’s natural senses, such as sight or hearing, of an awareness of place and time.102 Torture or cruel, inhuman or degrading treatment or punishment or a breach of Article 10(1) of the ICCPR may also occur when a detainee requires individualised treatment. The following are examples of situations where the detainee’s personal circumstances imposed particular obligations: • A detainee was born with phocomelia, a congenital malformation in which the hands and feet are attached to abbreviated limbs. The ECHR held that to detain a severely disabled person in conditions where she is dangerously cold, risks developing sores because her bed 97 Dougoz v Greece, judgment of the ECHR, 6 March 2001 at [46]. Wilson v Philippines Communication 868/1999: Philippines. 11/11/2003. CCPR/C/79/D/868/1999 at [7.3]. 99 Howell v Jamaica Communication No. 798/1998: Jamaica. 07/11/2003. CCPR/C/79/D/798/1998 at [6.2]. 100 Yasseen and Thomas v Guyana Communication No. 676/1996: Guyana. 07/05/98. CCPR/C/62/D/676/1996 at [7.4] and [7.6] 101 Lewis v Jamaica Communication No. 527/1993: Jamaica. 18/11/96. CCPR/C/57/D/527/1993 at [10.4]. 102 See footnote 1 to Principle 6 of Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment 1988. 98 81