21 60. In particular, international case law and the following authorities have considered that corporal punishment is incompatible with international guarantees against torture and other cruel, inhuman or degrading treatment. 61. The United Nations Special Rapporteur on Torture has stated that Article 31 of the United Nations Standard Minimum Rules for the Treatment of Prisoners reflects the international prohibition of cruel, inhuman or degrading treatment, and, more broadly, that "corporal punishment is inconsistent with the prohibition against torture, and cruel, inhuman or degrading treatment or punishment enshrined, inter alia, in the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the Declaration on the Protection of All Persons from Being Subjected to Torture, Cruel, Inhuman or Degrading Treatment or Punishment, and the Convention against Torture, Cruel, Inhuman or Degrading Treatment or Punishment.”17 62. Similarly, the United Nations Human Rights Committee has concluded that the prohibition of torture and cruel, inhuman or degrading treatment or punishment contained in Article 7 of the International Covenant on Civil and Political Rights should be extended to corporal punishment, “including excessive chastisement ordered as punishment for a crime, or as an educative or disciplinary measure”.18 With respect to the use of corporal punishment in Trinidad and Tobago, the Committee specified in its Concluding Observations on a report submitted by Trinidad and Tobago under Article 40 of the Covenant that it was “disturbed to learn that apart from prohibiting corporal punishment for persons under 18 years of age, the State party is still practicing the punishment of flogging and whipping which are cruel and inhuman punishment prohibited by article 7.” It thus recommended that the State immediately abolish all sentences of flogging or whipping.19 63. The Human Rights Committee has reached similar conclusions in its decisions on individual complaints. For example, in the case of Sooklal v. Trinidad and Tobago, the Committee ruled that the administration of birching provided for by the law of the State as a sanction constitutes cruel, inhuman or degrading treatment or punishment contrary to Article 7 of the Covenant. Similarly, in the case Osbourne v. Jamaica, the Committee found that by carrying out a sentence of whipping with a tamarind switch, the State party had breached its obligations under said provision.20 In that ruling the Committee stated that: 17 "Questions of the Human Right of all Persons subjected to any form of detention or imprisonment, in particular: torture and other Cruel, Inhuman or Degrading Treatment or Punishment". Report of the Special Rapporteur, Mr. Nigel S. Rodley, submitted pursuant to Commission on Human Rights res. 1995/37 B, 10 January 1997, E/CN.4/1997/7. 18 UNHRC, General Comment 20, Article 7 (44th sess., 1992), Compilation of General Comments and General Recommendations adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.1 at 14 (1994), para. 5; and UNHRC, General Comment 21, Article 10 (44th sess., 1992), Compilation of General Comments and General Recommendations adopted by Human Rights Treaty Bodies, U.N. Doc. HRI/GEN/1/Rev.1 at 14 (1994), para. 3. 19 UNHRC consideration of reports submitted by states parties under Article 40 of the Covenant, Concluding observations of the Human Rights Committee: Trinidad and Tobago, Seventieth session, November 3, 2000, CCPR/CO/70/TTO, para. 13. 20 Osbourne v. Jamaica, Communication No. 759/1997, Report of the Human Rights Committee, April 13, 2000, CCPR/C/68/D/759/1997, para. 9.1. See also UNHRC, Boodlal Sooklal v. Trinidad and Tobago, Communication No. 928/2000, Report of the Human Rights Committee, November 8, 2001, CCPR/C/73/928/2000, para. 4.6; and Matthews v. Trinidad and Tobago, (569/1993) Report of the Human Rights Committee, 29 May 1998, CCPR/C/62/D/569/1993, para. 7.2.