MERITS The Complainants submission on the Merits Alleged Violation of Article 5 of the African Charter 122. The Complainants submit that the acts of torture and ill-treatment perpetrated upon the Victim, violates Article 5 of the African Charter, which prohibits "[a]ll forms of exploitation and degradation of man particularly slavery, slave trade, torture, cruel, inhuman or degrading punishment and treatment". 123. The Complainants submit that the Commiscsion in interpreting Article 5 of the African Charter, referred to Article l .of the UN Convention against Torture and other Cruel, Inhuman ,or Degrading Treatment of Punishment (UNCAT),31 and .has drawn o:n . · the jurisprudence of the European Court of Hqman Rights on Artjcle 3 of the European Convention on Human Rights3 2• 124. The Complainants argue that as recognized by Article 1 of the UNCAT, the European Court of Human Rights 33 and the jurisprudence of the Commissi~n, psychological trea.t ment - such as death threats, instilling fear, solitary confinement, and humiliation - may constitute torture or cruel, inhuman or degrading treatment or punishment. As the Commission has recognized, . the term 'cruel, inhuman or degrading punishment or treatment' "is; to be interpreted so as to extend to the widest possible protection against abuses, whether physical or mental" 34 . Moreover, the Complainants argue that the Commission held that 'inhuman or degrading treatment "includes not only action which