is too hard or unreachable, and is unable to go to the toilet or keep clean without the greatest of difficulty, constitutes degrading treatment.103 • Continued detention constituted ill-treatment when the State party was aware of the detainee’s mental condition and failed to take the steps necessary to ameliorate his mental deterioration.104 Detention: use of force The Code of Conduct for Law Enforcement Officers105 and the Basic Principles on the Use of Force106 contain specific guidelines on the use of force and security measures. Article 3 of the Code of Conduct for Law Enforcement Officials provides that “[l]aw enforcement officials may use force only when strictly necessary and to the extent required for the performance of their duty.” The commentary on Article 3 provides a guide to when force can be used: • Force may be necessary for the prevention of crime or to effect or assist in the lawful arrest of an offender or suspected offender, but no force going beyond that may be used. • Any force used must be proportionate to the objective to be achieved. • However, force used for the purpose of retaining or disciplining a detainee is not referred to. General Provision 4 of the Basic Principles on the Use of Force states that: Law enforcement officials, in carrying out their duty, shall, as far as possible, apply non-violent means before resorting to the use of force and firearms. They may use force and firearms only if other means remain ineffective or without any promise of achieving the intended result. 103 Price v United Kingdom, judgment of the ECHR, 10 July 2001 at [30]. C v Australia, Communication No 900/1999: Australia. 13/11/2002. CCPR/C/76/D/900/1999 at [8.4]. 105 Adopted by UN General Assembly resolution 34/169 of 17 December 1979. 106 Adopted by the Eighth UN Congress on the Prevention of Crime and the Treatment of Offenders, Havana, Cuba, 27 August to 7 September 1990. 104 82