30. General damages are items of harm or loss suffered, for which only a subjective value may be attached. Examples of this might be pain, physical suffering, emotional trauma or suffering, loss of companionship, loss of consortium, disfigurement, loss of reputation, loss or impairment of mental or physical capacity, loss of enjoyment of life, etc. 31. Generally, punitive damages are not awarded in order to compensate the plaintiff, but in order to reform or deter the defendant and similar persons from pursuing a course of action such as that which damaged the plaintiff. Punitive damages are awarded only in special cases. 32. Having concluded in issues 1 and 2, above, that the plaintiff’s right to his personal liberty has been abused, the plaintiff is entitled to some damages for the wrongs that he has suffered. The amount of damages, however, is dependent on the facts of this application and the relevant rules governing the award of damages. Learned Counsel for the plaintiff prayed this honourable Court to award the sum of $ 5 000 000 as compensation to the plaintiff for his unlawful arrest and detention. Counsel stated that the essence of this Court awarding such a substantial amount is to deter other member states of the Community from engaging in violations of the human rights of Community citizens contrary to their obligations under domestic and international law. Counsel urged this Court to award some punitive damages in favour of the plaintiff in order to deter governments of member states from infringing on the rights of Community citizens with impunity. However, as stated earlier, punitive damages are awarded only in limited circumstances as it is not awarded to compensate the plaintiff but to deter the defendant and others from very reprehensible behaviour. 33. Although this Court is not bound by the precedents of other international courts, it can draw some useful lessons from their judgments, especially when the issues involved are similar: in other words, such decisions can be of persuasive value to this Court. 34. The European Court of Human Rights has awarded damages to successful plaintiffs whose human rights were violated by various governments of the European Union. In Selmouni v France [2005] CHR 237, the European Court of Human Rights awarded damages to the plaintiff who established to the satisfaction of the Court that the treatment meted out to him by the French authorities amounted to torture, inhuman and degrading treatment contrary to the provisions of article 25 of the European Convention for the Protection of Human Rights and Fundamental Freedoms. 35. The European Court of Human Rights similarly awarded damages to the plaintiff in the case of Cenbauer v Croatia [2005] CHR 429 when the Court held that he had been treated in a way that violated article 25 of the European Convention on Human Rights. 36. Notwithstanding the fact that the European and the Inter-American Courts have been in existence for long, there is no record available to us that showed that any of them had awarded punitive damages in a human rights cause. 37. In the European Court of Human Rights, applicants first argued for the award of punitive damages in the case of Silver and Others v. United Kingdom, 5 EHRR 347, 61 Eur Ct HR (ser A). This case was referred to the Court in March 1981 by the European Commission of Human Rights. The case originated in seven applications against the United Kingdom of Great Britain and Northern Ireland lodged with the Commission on various dates between 1972 and 1975. The applicants complained that the stopping by the prison authorities of a number of letters written by or addressed to them constituted a violation of articles 8 and 13 of the European Convention of Human Rights and asked for general damages for violation of their rights. In addition, three of the applicants claimed punitive damages against the government of the United Kingdom . Among the issues for determination by the Court was whether the acts complained of by the applicants amounted to a violation of their rights under articles 8 and 13 and whether the applicants were entitled to the damages sought, including that of the punitive damages. By judgment of 25 March 1983, the Court held that the stopping by the prison authorities of a number of letters written by or addressed to the applicants had given rise to violations of articles 8 and 13 of the Convention. The Court, however, denied the request for punitive damages, without discussing the merits or otherwise in the claim. The attitude of the Court in the case cited above clearly indicated that the Court was not in favour of awarding punitive damages in a human rights cause such as the one that was before them. 38. In Anufrijeva and Another v Southwark London Borough Council; R (Mambakasa) v Secretary of State for the Home Office; R(N) v Secretary of State for the Home Office[2004] QB 1124 it was held that Where an infringement of an individual’s human rights has occurred, the concern will usually be to bring the infringement to an end and any question of compensation will be of secondary, if any, importance.