A/HRC/58/49 62. The Bangkok Rules elucidate the gender dimension of this, stating that women prisoners from different religious backgrounds “have distinctive needs and may face multiple forms of discrimination in their access to gender- and culture-relevant programmes and services” and thus should be provided with “comprehensive programmes and services that address these needs”.90 63. The jurisprudence on this topic has largely observed these rules in relevant cases. For example, the Human Rights Committee found a violation of freedom of religion or belief in relation to a victim who claimed that he had been forced into an “ideology conversion system” due to a perceived idea that he was a communist. The author spent 13 years in solitary confinement for seemingly holding such convictions; however, the Committee did not consider it torture due to questions related to jurisdiction ratione temporis.91 64. In some instances, the Human Rights Committee has found a violation of both article 7 and article 18. In a case concerning the arrest of Jehovah’s Witnesses in Turkmenistan and subsequent ill-treatment in prison, the Committee found that the victims had their right to freedom of religion or belief violated because of systemic discrimination and “impediments to their religious activities”. The finding of a violation of the prohibition of torture was due to one of the authors being repeatedly beaten by prison officials and threatened with rape.92 Although the State had violated both rights, the reasons for those findings were based on distinct actions. In other words, the finding of torture or ill-treatment was not recognized on the basis of an aggravated violation of the right to freedom of religion or belief. 65. Similarly, the European Court of Human Rights held in a case that a prisoner’s inability to participate in religious services and being denied visits from a priest amounted to a violation of freedom of religion or belief. The Court also determined separately that the applicant had been subjected to beatings and other forms of ill-treatment in detention, constituting a violation of article 3.93 66. In their inputs, civil society organizations raised concerns regarding: the torture of Libyan prisoners, with an alleged renouncing of faith due to ill-treatment in one case; individuals professing their lack of religious beliefs being labelled as mentally ill and held against their will in psychiatric wards in an attempt to force them to change their beliefs; religious leaders being tortured and pressured to renounce their beliefs; and detainees belonging to minority groups being physically abused, threatened and coerced to renounce their faith.94 National preventive mechanisms in Estonia and Slovenia provided submissions stating that they had dealt with cases of inadequate alternatives to, or unreasonable delays in, the provision of food during Ramadan. 95 A submission from Bangladesh reported that 75 per cent of reported abuses against religious minorities in detention were not investigated.96 67. Further inputs concerned alleged violations of both rights where members of religious minorities are arbitrarily imprisoned merely because of their beliefs. 97 One submission reported that religious detainees had been systematically denied the ability to observe their 90 91 92 93 94 95 96 97 GE.24-24412 Bangkok Rules, rule 54. See also Istanbul Protocol, as revised, para. 282. Kang v. Republic of Korea (CCPR/C/78/D/878/1999), paras. 3.1, 3.2, 3.7, 6.3, 7.2 and 8. Nuryllayev and Salayev v. Turkmenistan (CCPR/C/125/D/2448/2014), paras. 7.2, 7.5 and 7.6. Poltoratskiy v. Ukraine, Application No. 38812/97, Judgment, 29 April 2003, paras. 120–149, 166 and 171. Submissions from World Evangelical Alliance, Humanists International, Forum 18, and Bangladesh civil society organizations. Submissions from national preventive mechanisms in Estonia and Slovenia. Submission from Bangladesh civil society organizations. Submissions from the Office of Public Information of Jehovah’s Witnesses, World Evangelical Alliance, Myanmar Freedom of Religion or Belief Network, Forum 18, International Human Rights Committee, Conscientious Objection Watch and Norwegian Helsinki Committee’s Freedom of Belief Initiative, Bangladesh civil society organizations, Humanists International, and Bahrain Centre for Human Rights. 13