Committee Against Torture (CAT) of preventing torture and ill-treatment. It runs counter to the universal Guidelines on NPMs of the UN Subcommittee on Prevention of Torture. c) Should it be applied under the stated format and before it is subject to further national and international consultations, the law by decree will tarnish the image and standing of the State of the Palestine before the Subcommittee on Prevention of Torture and other UN treaty bodies. It casts doubts on how serious the national will is to prevent torture. The ICHR called on relevant bodies to put enforcement of the law by decree on hold for further consultations with relevant stakeholders. The enactment needs to be amended in accordance with the OPCAT and Guidelines on NPMs. d) The law by decree does not entitle the National Commission against Torture to carry out unannounced visits to detention facilities. Rather, it stipulates prior arrangements for visits, never allowing the Commission to make some unannounced visits to certain cases in certain emergency circumstances. These visits do not require a long interval between a request for permission and actual implementation of visits. • In relation to deaths inside detention facilities The report is devoid of any reference to the incidents of death inside detention facilities in the West Bank and Gaza Strip. Apart from compensations paid by the State, the report does outline formal actions taken for investigation or procedures for administrative and criminal accountability of persons accused of the deaths, which investigations establish that they were caused by torture and other forms of cruel, inhuman and degrading treatment. According to ICHR annual reports on the situation of human rights in the Palestinian territory 2015-2021, the number of announced deaths of inmates inside detention centres totalled 31, distributed as follows: 4 in 2015, 3 in 2016, 5 in 2017, 3 in 2018, 3 in 2019, 9 in 2020, and 4 in 2021.3 • Claims of torture and maltreatment according to ICHR documentation The State’s report refers to the administrative actions taken against a number of law enforcement officials, who were held administratively and criminally accountable for acts performed by them, impinging on the right to physical integrity by means of torture and other forms of cruel, inhuman and degrading 3 See ICHR annual reports, available at https://www.ichr.ps/en/reports/annual-reports. 13