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   Case summaries      Ireland v UK 5310/71

Ireland v UK 5310/71 [1978] ECHR 1 European Court of Human Rights

The case concerned the ill treatment of suspected IRA terrorists in interrogation. The use of five techniques sometimes referred to as disorientation or sensory deprivation were implemented. The five techniques include:
1. Wall standing - forcing detainees to remain for some hours in a stress position. They would be spread eagled against the wall with their fingers put high above the head with the weight being born by their fingers and toes.
2. Hooding - putting a bag over the detainees' heads and keeping it there all the time except during interrogation
3. Subjection to noise - a continuous and loud hissing noise prior to interrogation
4. Sleep deprivation
5. Deprivation of food and drink
Whilst there was no written authorisation of the use of the techniques, the techniques had been taught by the English Intelligent Centre.


The use of the five techniques constituted inhuman and degrading treatment and therefore violated Art 3 ECHR. The techniques did not amount to torture.

There is no definition of inhuman and degrading treatment or torture. It is left to be determined in the light of the circumstances of each particular case whether what occurred amounts to the specified treatment. Such a determination is an entirely subjective one. The Convention makes no provision against lesser forms of ill treatment. The treatment must be classified as inhuman or torture to come within the scope of Art 3. 

Back to lecture outline on Art 3 ECHR