If the use of force is unavoidable, General Provision 5 of the Basic Principles on the Use of Force states that officials shall: (a) Exercise restraint in such use and act in proportion to the seriousness of the offence and the legitimate objective to be achieved; (b) Minimise damage and injury, and respect and preserve human life; (c) Ensure that assistance and medical aid are rendered to any injured or affected persons at the earliest possible moment; (d) Ensure that relatives or close friends of the injured or affected person are notified at the earliest possible moment. In Robinson v Jamaica the HRC held that excessive force was used in violation of Articles 7 and 10, as the injuries that the detainee sustained to his head, back, chest and legs went beyond that which was necessary to remove forcefully a difficult prisoner from a cell.107 Detention: security within detention The use of restraints (such as shackles) during detention can constitute a violation of CAT or Articles 7 and/or 10 of the ICCPR, depending on the circumstances: • In Cabal and Bertran v Australia,108 the HRC held that shackling the applicants with 12 or 17 link shackles during transport to and from prison and subjecting them to strips and cavity searches after each visit did not violate the ICCPR. The treatment was justified because the prisoners posed very high flight risks. Further, the detainees were not singled out for searches, the manner of the searches minimised embarrassment and the searches were carried out to ensure the safety and security of the prison. • In Mouisel v France109 a prisoner developed leukaemia which became progressively more serious. The ECHR found that handcuffing the applicant while he was being escorted to 107 Robinson v Jamaica, Communication No. 731/1996: Jamaica. 13/04/2000. CCPR/C/78/D/731/2000 at [10.3]. Cabal and Bertran v Australia, Communication No. 1020/2001: Australia. 19/09/2003. CCPR/C/78/D/1020/2001 at [8.2]. 109 Mouisel v France, judgment of the ECHR, 14 November 2002 at [47]. 108 83