The beating of a detainee with a truncheon for the purpose of extracting a confession must be considered torture if it inflicts severe pain or suffering the beating of a detainee with a truncheon walking to and from a cell might amount to CIDT, but the beating of demonstrators in the street with the same truncheon for the purpose of dispersing an illegal demonstration or prison riot, for example, might be justified as lawful use of force by law enforcement officials.

Dr. Edston concluded that the complainant had been subjected to the following torture hit with blunt instruments stabbed with a screwdriver and a police truncheon burned with cigarettes, a heated screwdriver and possibly a branding iron beaten systematically on the soles of his feet attempted suffocation by introducing hot water into his nose rolling of the legs with bamboo rods sexual violence including rape.