ti"i~'\":ACH PR ~ j > ~.uxn::/. African Commission on Human and Peoples' Rights Human Rights our Collective Responsibility the electroshocks.s'' The Second Victim testified how the authorities' ill-treatment, including threats of rape, beatings and electroshocks, verbal abuse and forced nudity in front of others, left her in fear and shock.s? 97. The Complainants also added that under such circumstances the burden shifts to the Respondent State to convince the Commission that the allegations of torture raised by the Complainants are unfounded. The context of the Complainants' incommunicado detention and interrogation is such that available evidence is necessarily limited. However, the allegations of torture and ill-treatment are supported by the victim's " independent testimonies of similar ill-treatment.Zl The Complainants, therefore, submitted that the different forms of ill-treatment as outlined above singly amounted at least to ill-treatment, and taken together, to torture, contrary to Article 5 of the Charter. 98. Concerning the State's obligations to safeguard the right to dignity, the Complainants submitted that the authorities violated their right to dignity contrary to Article 5. Substantiating this the complainants cited. Purohit and Moore v The GambiaZ) with the Commission holding that exposing an individual to personal suffering and indignity violates the right to dignity that can. take many forms and will depend on the circumstance of each case.'? 99. As to what constitutes a violation of the right to dignity, the Complainants referred to Commission in Egyptian Initiative for Personal Rights & INTERIGHTS v Egypt,(cited above) at para 200 referring to the judgment of the European Court of Human Rights position in Campbell and Cosans v UK/3 that treatment is degrading when the person concerned has undergone humiliation or debasement in the eyes of others attaining a minimum level of severity assessed regarding the circumstances of the case. And specifically, about the treatment of a sexual nature citing Iwanczuk v Poland/4where the European Court of Human Rights held that the prison's guards' verbal abuses and First Victim's video testimony (transcribed and translated). See Annex 20 Written Testimony of Second Complainant. See Annex 18 70 Ibid., para.169 71 Communication 241/01, para. 57 68 69 74 Application no. 25196/94, Judgment of 15 November 2001, para 59 221 P age Africao( \ Union 'i The African Commissio