that where torture or ill-treatment does arise, the Respondent State is obliged to respond with effective investigation and remedial action. The importance of such measures they argue, lies firstly, in acting as a deterrent to the commission of torture and ill-treatment and, secondly, in ensuring that where torture and other ill-treatment occurs, it is investigated and documented. The Complainants refer the African Commission to General Comment No. 2 of the Committee against Torture, which recognized judicial remedies and access to counsel and to medical assistance during detention as “baseline” guarantees which the state is obliged to respect in order to give effect to the obligation to prevent and protect against torture or ill-treatment.25 112. The Complainants argue that under the African Charter, a parallel obligation to prevent torture or ill-treatment derives from the undertaking given by the States Parties in Article 1 of the Charter “to adopt legislative or other measures to give effect” to the rights contained in the Charter. The importance of such safeguards, the Complainants argue, has been recognized by the African Commission in the Robben Island Guidelines.26 The Complainants aver that, the Commission itself has noted that while “punishment of the torturer is important, […] preventive measures such as halting of incommunicado detention, effective remedies under a transparent, independent and efficient legal system, and ongoing investigations into allegations of torture”27 are the best ways to deal with such atrocities. 113. It is submitted by the Complainants that, the victims were subjected to torture and ill-treatment by state agents – members of the security forces – while they were in state custody. They argue that, the victims were subjected to repeated electric shocks, beatings, prolonged hanging, binding and blindfolding aimed at their complete disorientation. They further state that, 25 Committee against Torture, General Comment No. 2, para. 13. 26 Robben Island Guidelines, para. 20. 27 See Amnesty International and others v. Sudan (Comm. nos 48/90, 50/91, 52/91 and 89/93), para. 56. 28