× 162. As was emphasised by the Commission, ill-treatment must attain a minimum level of severity if it is to fall within the scope of Article 3 (art. 3). The assessment of this minimum is, in the nature of things, relative; it depends on all the circumstances of the case, such as the duration of the treatment, its physical or mental effects and, in some cases, the sex, age and state of health of the victim, etc. ). 2 There are six crimes to which the hadd (âfixedâ) penalties apply, namely: zina (fornication, Qurâan 24:2); qadhf (false accusation of fornication, Qurâan 24:4); sukr (drunkenness, prescribed in the Qurâan and Sunnah); sariqa (theft, Qurâan 5:38), ridda (apostasy), and haraba (rebellion, Qurâan 5:33). Also see Abdullahi Ahmed An- Naâim, Towards an Islamic Reformation: Civil Liberties, Human Rights, and International Law (1990) at 108 and accompanying endnotes). 5