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Published: Fri, 02 Feb 2018

Torture In Nigeria

An Assessement Of Procedures And Strategies For The International Protection Of Human Rights

Nigeria is notorious for human rights abuses. The State, via the police, military and security services, brutalises the citizens. This essay sets out to discuss torture as one of the human rights abuses in Nigeria. It will also discuss the United Nations’ and the Nigerian Government’s responses to the situation.

It is submitted that Nigeria operates a very fragile democracy. The rule of law hardly ever obtains in practice. There are three most observable contexts in which torture occurs in Nigeria. The Sharia [Islamic] law permits torture, the Police resort to torture to extract confessions or to obtain further information in relation to alleged crimes and torture occurs for economic reasons as evidenced by the volatile situation in Ogoniland.

In the religious context, twelve of Nigeria’s northern states are governed by Sharia law (Adamu 1 Jan. 2008; Denmark Jan. 2005, 50), and there are varying formulations of Sharia (Islamic law) in these states. Sharia courts deliver sentences involving amputation, caning and stoning all of which are unconstitutional grounds but have yet to be challenged in the courts as a violation of the law. In the context of criminal investigation, the police, military, and security force officers regularly beat protesters, criminal suspects, detainees, and convicted prisoners, although they knew that such practices were against the law. The Human Rights Watch (HRW) (2003) and Amnesty International (AI) [February 2004] noted that ill-treatment and torture of detainees were widespread in Nigerian prisons. Also, Amnesty International (December 2002) noted that suspects endured torture and cruel, inhuman and degrading treatment while in custody at police detention centres. It reported the cases of four people who died after they were arrested and held in custody at police detentions centres; two were held at centres in the State of Enugu and the other two at centres in the city of Lagos (AI Dec. 2002).

Nigeria’s prison systems are unbearable, resulting in a high proportion of inmates’ deaths (IPS 6 Jan. 1999).  A representative from Human Rights Watch (HRW) stated that prison conditions are ‘…generally appalling/life threatening [and] torture of criminal suspects by the police is common,’ adding that torture is more common by police than prison officials (Manby 2 Mar 1999). A representative from the Civil Liberties Organization says, ‘The nature of torture in most Nigerian prisons is fluid,’ encompassing not only physical torture but mental torture.  He cited examples that prisoners are offered all three meals between the hours of 8:00 a.m. and 2:00 p.m. and that condemned prisoners are chained to each other (Onyeisi 3 Mar. 1999). The Amnesty International observed that, ‘There are regular reports of the torture and ill-treatment of prisoners, and prison conditions so harsh as to amount to cruel, inhuman and degrading treatment.’ (AI 22 Sept. 1997, 1)

Civil Liberties Organization [3 Mar, 1999] noted that people with past drug convictions overseas are, upon their return, detained under Decree 33 and tortured for bringing the name of Nigeria into disrepute. A representative from HRW states that it is common of deportees with drug convictions to be detained indefinitely by the National Drug Enforcement Agency (NDLEA) on return to Nigeria, unless the detainee has the means to buy himself out (Manby 2 Mar 1999). A representative of Amnesty International (AI) says that, although, there are no signs of deportees being charged and sent to trial on Decree 33, Nigerian authorities are more likely to be harsher towards a drug deportee, since Nigeria has a political interest with the United States (Pennington 10 Feb. 1999). Amnesty International stated that torture of a deportee under Abubakar was less likely opposed to when Abacha was in power. (Akwei 3 Feb. 1999) Harsh conditions and denial of medical treatment had led to many deaths in detention, mainly of prominent political detainees (Country Reports 1998). The United Nations Special Rapporteur for Nigeria, Soli Jahangir Sorabjee of India, said in a UN report that ‘…although Abubakar promised to undertake prison reform, torture and other inhuman treatment of prisoners was still reported…’ (AFP 29 Oct. 1998).

In their study the Nigerian Human Rights Commission and the NGO Centre for Law Enforcement (CLEEN) stated that almost 80 percent of inmates in Nigerian prisons claim to have been beaten by police, threatened with weapons and tortured in police cells. The UN Special Rapporteur on torture reported that torture and other ill-treatment in police custody are widespread and systemic, particularly in CID custody, stating ‘Torture is an intrinsic part of the functioning of the police in Nigeria’ and ‘at CID detention facilities, it was a challenge to find a detainee that had not been ill-treated.’ Buba Galadima, Chairman of the mobilization committee of the Conference of Nigerian Political Parties (CNPP), was reportedly arrested in Abuja on 29 April 2004 by officers from the State Security Services (SSS) (AI 30 Apr. 2004; Weekly Trust 1 May 2004). According to Amnesty International, Buba Galadima was suspected of being involved in an anti-government protest, and was being held incommunicado detention without charge and is at risk of torture or ill-treatment (AI 30 Apr. 2004).

Amnesty International has found that the Nigerian police force and security forces commit rape in many different circumstances, both on and off duty. The AI report noted that rape is at times used strategically to coerce and intimidate entire communities. This is particularly prevalent in the Niger Delta where rape has been committed by security forces deployed by the Federal Government. In some cases women were held for several weeks in sexual slavery in military barracks and repeatedly raped, and the perpetrators acted with impunity. The Civil Liberties Organization and Prisoners Rehabilitation and Welfare Action (PRAWA) identified rape and other forms of sexual violence, or the threat of such violence, as a method of torture used by the police in order to extract confessions or other information.

In a meeting with Amnesty International in July 2007, senior police officials at the federal headquarters of the Nigeria Police Force confirmed that they have received reports of torture and that they are addressing these unconventional ways of interviewing. In practice, observed the AI, any actions taken by the Nigeria Police Force have failed to end the use of torture in the interrogation of suspects. The Amnesty International noted that the government has allowed widespread torture to be carried out with impunity, as the Nigerian National Human Rights Commission highlights in its report on the state of human rights,

‘…the Nigerian Army, the Nigeria Police Force and other law enforcement agencies commit the act of torture with impunity.’

The Niger Delta is noted to be a heavily militarised area of Nigeria, where violence is used as an instrument of governance to force the people into total submission (Okonta and Douglas, 2001; Na’Allah, 1998). The region generated an estimated over US$30 billion in oil revenues over a 38-year period in the form of rents for the government and profit for the multinational oil companies (Rowell, 1996), yet its people live in abject poverty and its women are the poorest of the poor (Human Rights Watch, 2002; 2004; 2007). Chunakara (1994) noted that militarisation consists of the use of the threat of violence to settle political conflicts, the legitimisation of state violence, the curtailment of freedom of opinion, the domination of military values over civilian life, the violation of human rights, extrajudicial killings and the gross repression of the people. Turshen {1998) describes the militarised state as one in which ‘violence becomes a crisis of everyday life, is disenfranchising and politically, physically and economically debilitating’ (p 7).

The multinational oil companies, mainly Shell, Chevron/Texaco and Elf, work hand-in-hand with the Nigerian Government to torture the people, by providing the Nigerian military and police with weapons, transport, logistical support and finance (Okonta and Douglas, 2001). Ekine (2000) and Turner (2001) documented personal and community experiences of violence, stories narrated by women of rape, beatings, sexual harassment, burning of their property, arrest and murder of their husbands, sons, fathers and brothers by police and army personnel. Rape serves to gratify the soldiers, feeding their hatred of the enemy while also being used as an effective weapon of war, especially to spread terror amongst the people (Turshen and Twagiramariya, 1998). The Amnesty International’s Report [Nigeria: Rape – the Silent Weapon, 2006] also revealed how the police, security forces and the military notoriously raped women. The report maintained that women have been raped by the police while being transferred to police stations, while in police custody or even when visiting male detainees. It also mentioned cases of rape by security forces engaged in peace keeping operations in Ogoniland, Odi, Odioma, and Ugborodo, all in the Niger delta, and inadequate government response to address the incidents.

International Treaties:

Article 38[1] of the Statute of the International Court of Justice acknowledges that one of the sources of international law is international Conventions. Torture is prohibited by several international human rights treaties, which Nigeria ratified. She ratified the International Covenant on Civil and Political Rights of 1966, on 29 October 1993, the African Charter on Human and People’s Rights of 1981, on 22 June 1983, the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment of 1984, on 28 June 2001, and the Convention on the Elimination of All Forms of Discrimination against Women of 1979 (CEDAW)(1979), on 13 June 1985, and its Optional Protocol of 1999, on 22 November 2004. By ratifying CEDAW, Nigeria has undertaken to:

‘condemn discrimination against women in all its forms, agree to pursue by all appropriate means and without delay a policy of eliminating discrimination against women. ‘ (Art 2)

Article 5(a) of CEDAW is also particularly significant:

‘States Parties shall take all appropriate measures: (a) To modify the social and cultural patterns of conduct of men and women, with a view to achieving the elimination of prejudices and customary and all other practices which are based on the idea of the inferiority or the superiority of either of the sexes or on stereotyped roles for men and women.’

Articles 5 of the Universal Declaration of Human Rights [UDHR][1948] states, ‘No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment.’ The rights enshrined in the UDHR have been given effect by International Covenant on Economic, Social and Cultural Rights [1966], the International Convention on Civil and Political Rights [ICCPR] [1966] and of the African Charter on Human and Peoples’ Rights [ACHPR][1981]. The provisions of Art 5 of the UDHR were repeated verbatim by Art 7 of the ICCPR and Art 5 of the ACHPR.

Torture is a breach of individuals’ human rights. According to section 702 of the American Law Institute Restatement [Third] The Foreign Relations Law of the United States, ‘A state violates international law if, as a matter of state policy, it practices, encourages or condones, inter alia, torture or other cruel, inhuman or degrading treatment or punishment.’ Art 1 [1] of the Convention Against Torture states, ‘For the purposes of this Convention, torture means any act by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession, punishing him for an act he or a third person has committed or is suspected of having committed, or intimidating or coercing him or a third person, or for any reason based on discrimination of any kind, when such pain or suffering is inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting in an official capacity.’

Although the Convention against Torture does not specifically include rape, it has become accepted that rape is a form of torture. The UN Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment stated in 1992 that ‘Since it was clear that rape or other forms of sexual assault against women in detention were a particularly ignominious violation of the inherent dignity and the right to physical integrity of the human being, they accordingly constituted an act of torture’. The Committee on the Elimination of All Forms of Discrimination against Women has confirmed that the definition of discrimination against women contained in Article 1 of CEDAW includes ‘acts that inflict physical, mental or sexual harm or suffering, threats of such acts, coercion and other deprivations of liberty.’ Article 1, the protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa, ratified by Nigeria on 18 February 2005, defines violence against women as:

‘all acts perpetrated against women which cause or could cause them physical, sexual, psychological, and economic harm, including the threat to take such acts; or to undertake the imposition of arbitrary restrictions on or deprivation of fundamental freedoms in private or public life in peace time and during situations of armed conflict or of war.’

Rape entails a use of force. In Nicaragua v USA it was held that ‘the use of force could not be the appropriate method to … ensure respect’ for human rights. The Rome Statute, adopted in 1998 ratified by Nigeria in 2001, defines the crime against humanity of rape in Article 7(1)(g) of the Elements of Crimes:

‘1. The perpetrator invaded the body of a person by conduct resulting in penetration, however slight, of any part of the body of the victim or of the perpetrator with a sexual organ, or of the anal or genital opening of the victim with any object or any other part of the body.

2. The invasion was committed by force, or by threat of force or coercion, such as that caused by fear of violence, duress, detention, psychological oppression or abuse of power, against such person or another person, or by taking advantage of a coercive environment, or the invasion was committed against a person incapable of giving genuine consent.’

The Rome Statute recognized, inter alia, rape as one of the crimes against humanity. The Rome Statute also criminalizes gender-based persecution (Art. 7(2)(h)), and ‘outrages upon personal dignity, in particular humiliating and degrading treatment.'(Art. 8 (2)(xvi))

Rape violates the rights of women and girls to be free from torture. For rape to amount to torture, it must have been intentionally committed by or at the instigation of, or with the consent or acquiescence of a public official or another person acting in an official capacity for purposes such as obtaining information or a confession from the victim or a third person; punishing the victim; intimidating or coercing the victim or a third person; or for any reason based on discrimination of any kind. Torture also infringes s.34(a) of Nigeria’s 1979 Constitution, which states, ‘No person shall be subjected to torture or to inhuman and degrading treatment.’ This means that anybody who is a victim of torture is free to seek legal redress in the domestic courts.

Despite s.34 of the 1979 Nigerian Constitution, article 7 of ICCPR and the Convention against Torture, Amnesty International [2006, op cit] noted that torture and rape were still widespread. Thus, stoning and beating to give effect to Sharia law and the use of batons and teargas to control crowds during protests in Nigeria constituted torture, inhuman and degrading treatment. These imply a use of force, which run against the spirit of Nicaragua v USA above. States that fail to exercise due diligence to prevent, stop, investigate, prosecute and provide reparations for violence against women, wherever it occurs, may be held accountable for violating their rights under international human rights law. Articles 2(1) and 3 of the ICCPR, provide that:

‘2(1). Each State Party to the present Covenant undertakes to respect and to ensure to all individuals within its territory and subject to its jurisdiction the rights recognized in the present Covenant, without distinction of any kind, such as race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status.”

3. The States Parties to the present Covenant undertake to ensure the equal right of men and women to the enjoyment of all civil and political rights set forth in the present Covenant.’

The Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa, specifically obliges states to adopt appropriate and effective measures to enact and enforce laws to prohibit all forms of violence against women, including unwanted or forced sex, to punish the perpetrators of violence against women, and implement programmes for the rehabilitation of women victims. Art 4 of the Protocol states, ‘Every woman shall be entitled to respect for her life and the integrity and security of her person. All forms of exploitation, cruel, inhuman or degrading punishment and treatment shall be prohibited’, and Art 5 obliges states to ‘prohibit and condemn all forms of harmful practices which negatively affect the human rights of women and which are contrary to recognized international standards.’

Art 1 of the Optional Protocol to the International Covenant on Civil and Political Rights [1966] states, ‘A State Party to the Covenant that becomes a Party to the present Protocol recognizes the competence of the Committee to receive and consider communications from individuals subject to its jurisdiction who claim to be victims of a violation by that State Party of any of the rights set forth in the Covenant. No communication shall be received by the Committee if it concerns a State Party to the Covenant which is not a Party to the present Protocol.’ Art 8 of the UDHR states, ‘Everyone has the right to an effective remedy by the competent national tribunals for acts violating the fundamental rights granted him by the constitution or by law.’ Art 7[1] of the ACHPR states, ‘Every individual shall have the right to have his cause heard. This comprises: (a) the right to an appeal to competent national organs against acts of violating his fundamental rights as recognized and guaranteed by conventions, laws, regulations and customs in force…’ Art 2 of the Optional Protocol to CEDAW [1999] entitles female victims to bring their complaints to the UN.

Efforts by victims of rape have been frustrated by the Police through bribery and intimidation. Amnesty International’s report [2006, op cit] observed that the perpetrators of rape and other sexual offences against women seem to be taking advantage of the difficulties associated with reporting cases of rape by victims. These obstacles include societal stigmatization, intimidation by the police, indifference of the state and the knowledge that the perpetrator is unlikely to be brought to book. Victims are sometimes pressured into withdrawing the case or their parents prefer financial settlement out-of -court to a criminal prosecution. Where cases are brought to court, prosecutions sometimes fail because police refer cases to courts lacking jurisdiction and progress is then obstructed by the slow administration of the judicial system. In some cases the alleged perpetrator is charged with a less serious criminal offence. In a few cases where convictions are secured, judges seldom impose the maximum sentence, thus demonstrating an apparent failure of the judiciary to acknowledge the gravity of the crime. In addition, compensation is rarely awarded because of the absence of appropriate legislation.  

The United Nations Responses:

The Amnesty International (AI) reported that, ‘There are regular reports of the torture and ill-treatment of prisoners, and prison conditions so harsh as to amount to cruel, inhuman and degrading treatment.’ (AI 22 Sept. 1997, 1) The United Nations Special Rapporteur for Nigeria, Soli Jahangir Sorabjee of India, said in a UN report that, although Abubakar promised to undertake prison reform, torture and other inhuman treatment of prisoners was still reported (AFP 29 Oct. 1998). It was recommended that the Abubakar government get rid of the “…relics and infrastructures of torture and oppression created by the dictatorship of Abacha that still remain in place…” (IPS 6 Jan. 1999)

During his visit to Nigeria in March 2007, the Special Rapporteur welcomed Nigeria’s commitment to promoting respect for human rights, as demonstrated by, among other things, its democratic principles, the existence of a vibrant media, dedicated civil society organizations, membership of the United Nations Human Rights Council, and its record of cooperation with international human rights mechanisms and organizations. He appreciated the challenges the State faced given the sheer size and diversity of the population, including ethno-linguistic and religious groups, the plurality of legal systems, the nature of the federal structure, the high level of crime, widespread poverty (despite the potential enormous wealth from oil revenues), and the conflict in the Niger Delta. The Special Rapporteur regretd, however, that the State Security Service denied him access to their detention facilities on each of the three occasions he attempted to visit. This constitutes a serious breach of the terms of reference agreed upon by the Government. Since he received credible allegations of torture by this intelligence agency, the denial of his right to assess for himself the allegations by inspecting the facilities and interviewing detainees lead him to strongly suspect that the authorities wished to conceal evidence.

The Special Rapporteur noted that corporal punishment, such as caning, and including Sharia penal code punishments, particularly in northern states (i.e. amputation, flogging and stoning to death), remain lawful in Nigeria. He recalled that any form of corporal punishment was contrary to the prohibition of torture and other cruel, inhuman or degrading treatment or punishment. He concured fully with the analysis of the United Nations Special Rapporteur on summary, arbitrary and extra-judicial executions, who carried out a visit to the Nigeria in 2005, that virtually every component part of the criminal justice system functions badly, that each group contributing to the problem, police officers, politicians, and the judiciary, was content to blame the other and that there was no question about accountability of perpetrators because there are no functioning complaint mechanisms which exist to receive allegations, and to report and seek effective redress for acts of torture. Victims, especially those still in detention, have no confidence in the mechanisms that do exist, such as reporting allegations directly to senior police officials, or to the Human Rights Desks (in those stations where they exist).

Special Rapporteur noted that, although victims knew that police abuse was wrong, felt powerless and were resigned to accept that impunity was the natural order of things when it came to Nigerian law enforcement. Moreover, attempts to register complaints may be met with intimidation; or investigations lack independence as they may be conducted by the police themselves, or are dealt with internally. Forensic medical examinations which could sustain complaints are non-existent even in cases of death in police custody. No information was provided by the Government on evidence of successful criminal prosecutions of perpetrators for torture, or payment of compensation to victims.

He concluded that ‘torture and ill-treatment is widespread in police custody; particularly systemic in the Criminal Investigation Departments’. The Special Rapporteur recommends that the Government takes decisive steps in order to implement its obligation under its constitution and international law. In particular, the Special Rapporteur recommends the Government, together with the assistance of the United Nations and other actors, to:

· criminalize torture in full accordance with the definition contained in article 1 of the Convention against Torture, and impose appropriate penalties;

· undertake a concerted effort to fight impunity by establishing an independent and powerful a criminal investigation mechanism against perpetrators of torture similar to the efforts of the Government’s campaign against corruption;

· undertake a nation-wide, sustained and effective awareness campaign on the absolute prohibition of torture and ill-treatment;

· introduce effective complaints mechanisms within places of detention, and strengthen the National Human Rights Commission to become an effective body which can monitor the practice of torture and ill-treatment;

· introduce effective measures aimed at preventing torture, such as medical documentation of torture allegations, access to lawyers by expanding free legal aid, and monitoring of interrogation methods;

· abolish all forms of corporal punishment, and take further steps towards the abolition of capital punishment;

· establish effective mechanisms to enforce the prohibition of violence against women including traditional practices such as FGM, and continue awareness-raising campaigns to eradicate such practices, and expedite the adoption of the Violence against Women Bill;

· ratify the Optional Protocol to the Convention against Torture, and establish effective national mechanisms to carry out preventive and unannounced visits to all places of detention;

· fight corruption in the police and prison system by ensuring adequate salaries to law enforcement and prison personnel.

The findings of Amnesty International confirm those of the UN Special Rapporteur on Torture. Amnesty International urged the African Commission to publicly condemn the human rights violations by the Nigerian Government and its law enforcement agencies. The African Commission should also call on Nigeria to ensure the full respect and protection of the human rights enshrined in the African Charter on Human and Peoples’ Rights; investigate all allegations of human rights abuses and, if there is sufficient admissible evidence, to prosecute the suspected perpetrators; ensure prompt and fair trials for those accused of a criminal offence in accordance with international and regional standards and without recourse to the death penalty. Amnesty International therefore recommends that the definition of rape by the Rome Statute be incorporated fully into domestic law so as to maximize the protection of the human rights of women and girls and to ensure the right to redress and reparations in cases of rape.

In its report, Amnesty International observed that prosecutions for rape are brought only in a limited number of cases. It noted that investigations by the government into human rights violations (covering the period of 1966-1999) by the security forces in Ogoniland has been limited to the work of the Oputa Panel. Although other cases from the Niger Delta may have been considered, those from Ogoniland were prominent during the Oputa Panel Hearings. The panel’s public hearings included sessions in Port Harcourt where the experiences of victims, including women who had been raped by members of the security forces, and their families were documented. It also noted that the report of the Panel was submitted to the Federal Government in May 2002 but has yet to be made fully public and accessible to the Nigerian people. No one has been brought to justice for the human rights violations committed in Ogoniland and no reparations have been awarded to the victims, many of whom continue to suffer the physical and psychological effects of these violations more than 10 years later.

Its recommendations include initiation of public education programmes on ending violence against women, domestication of the UN Convention on the elimination of all Forms of Discrimination against Women (CEDAW), systematic and comprehensive documentation of cases of violence against women, harmonization of punishment for rape with the gravity of the crime, provision of gender sensitivity training to the police and security forces, judges, and other officials in the criminal justice system, and lawyers, repeal of the Public Officers Protection Act to ensure it does not prevent or hinder prosecution of state actors charged for rape, and urgent publication of the report and recommendations of the Committee on the Review of Discriminatory Laws against Women as well as an action plan for its implementation.

The 2007 Mission to Nigeria report of the United Nations (UN) Special Rapporteur on Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment provides an overview of the complaint mechanisms available to victims of police abuse (UN 22 Nov. 2007, Para. 29-33). The report states that:

oral or written complaints of police misconduct by members of the public can be made to any superior police officer about acts of misconduct involving his or her subordinates, and if the complainant is dissatisfied with the response, he or she could complain in writing to higher officers, including the IGP [Inspector General of Police]. Complaints could also be sent to the police Public Complaints Bureau (PCB) located in the police public relations department of every state police command, or to the police Provost Department at the Force headquarters. In addition, Human Rights Desks for receipt of complaints have been established in recent years for each state command. (ibid., Para. 29)

The report further notes that individuals may also make complaints about human rights violations, in writing or orally, to Nigeria’s National Human Rights Commission (NHRC), which is mandated to investigate human rights violations (ibid., Para. 32). Nevertheless, the UN report and other sources consulted by the Research Directorate indicate that these complaint mechanisms have not been effective and that the police commit abuses with impunity (ibid., Para. 41; Denmark Jan. 2005, 32-33; HRW July 2005, 56-58, 60; NOPRIN 10 Dec. 2007, 10-11). A 2005 report by Human Rights Watch (HRW) states that the NHRC is “acutely under-resourced, and lacks judicial power to enforce redress” (July 2005, 62). According to the Special Rapporteur, victims of police abuse lack confidence in the complaints mechanisms and the majority do not have access to these mechanisms (e.g., they cannot afford lawyers) (UN 22 Nov. 2007, Para. 41).

According to HRW, in cases where individuals, lawyers and human rights organizations have attempted to register complaints, the Nigerian police have created obstacles to prevent investigation or prosecution (e.g., by intimidating witnesses, bribing victims or their families to drop their complaint, or conspiring with judicial authorities to have cases dismissed) (July 2005, 57; see also UN 22 Nov. 2007, Para. 43). In its 2005 report, HRW notes that very few cases of police misconduct have been fully investigated (July 2005, 58). Several sources cited in the 2005 British-Danish Fact-Finding Mission report similarly indicate that few cases of police misconduct are investigated and prosecuted (Denmark Jan. 2005, 33). Cases of police “brutality” are reportedly investigated only if the victims are well-connected or are considered “influential” individuals, or if the cases have received the attention of the media or of politicians, after being brought to light by non-governmental organizations (NGOs) or other observers (ibid.). In his concluding remarks in his Mission to Nigeria report, the Special Rapporteur states that ‘torture is an intrinsi

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