and from hospital for treatment was a disproportionate measure that amounted to inhuman and degrading treatment. The Court took security requirements into account but considered that the applicant’s state of health made handcuffing unnecessary. • In Iwanczuk v Poland110 permission for the detainee to vote in parliamentary elections while he was awaiting trial on fraud charges was subject to a body search. The applicant was subjected to humiliating remarks about his body and verbal abuse. Permission to vote was denied when he refused to remove his underpants. The ECHR held that the applicant had been subjected to degrading treatment, as there were no compelling reasons to justify the strip search. The applicant had no previous convictions or history of violence and the search was intended to cause feelings of humiliation and inferiority. Detention: force-feeding Force-feeding a detainee involves degrading elements which, in certain circumstances, can contravene the prohibition on torture and other forms of ill-treatment. In X v Germany the prisoner was on a hunger strike. The European Commission was satisfied that the authorities acted solely in the best interests of the applicant when choosing between either respecting his will not to accept nourishment, and thereby incurring the risk of injuries or death, or taking action to secure his survival, although such action might infringe the applicant’s human dignity.111 Detention: blind folding In Öcalan v Turkey112 the applicant was arrested on suspicion of having committed serious terrorist offences. He was blindfolded from the moment of his arrest in Kenya until his arrival in prison in Turkey the following day. The ECHR held that blindfolding the suspect did not amount to inhuman or degrading treatment in the circumstances, as the applicant was blindfolded for reasons of security and was not interrogated while blindfolded. 110 Iwanczuk v Poland, judgment of the ECHR, 15 November 2001. X v Germany (1984) 7 EHRR 152 at [153-154]. 112 Öcalan v Turkey, judgment of the ECHR, 12 March 2003. 111 84

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