92 M.S.S. v. BELGIUM AND GREECE JUDGMENT – SEPARATE OPINIONS [Office of the United Nations High Commissioner for Refugees] and the standards set out in the Reception Directive”. Indeed, this last European document clearly requires that the European Union’s member States guarantee asylum-seekers “certain material reception conditions, including housing, food and clothing, in kind or in the form of financial allowances. The allowances must be sufficient to protect the asylum-seeker from extreme need” (see paragraph 84). The existence of those international obligations of Greece – and notably, vis-à-vis the European Union – to treat asylum-seekers in conformity with these requirements weighed heavily in the Court’s decision to find a violation of Article 3. The Court has held on numerous occasions that to fall within the scope of Article 3 ill-treatment must attain a minimum level of severity. The assessment of this minimum is relative and it depends on all the circumstances of the case (such as the duration of the treatment, its physical and mental effects and, in some instances, the sex, age and state of health of the victim). In the circumstances of the present case, the combination of the long duration of the applicant’s treatment, coupled with Greece’s international obligation to treat asylum-seekers in accordance with what the judgment calls current “positive law”, justifies the distinction the Court makes between treatment endured by other categories of people – where Article 3 has not been found to be transgressed – and the treatment of an asylum-seeker, who clearly enjoys a particularly advanced level of protection.