serious form of gender violence under the provisions of the American Convention and the Convention of Belém do Pará. 1.2.3. Analysis of the physical, psychological, and sexual violence based on the absolute ban on and cruel, inhuman, and degrading treatment and punishments 1.2.3.1. General considerations 200. The Inter-American Commission dealt with sexual violence as torture in the cases of Raquel Martín de Mejía v. Perú273 and Ana, Beatriz, and Celia González Pérez v. Mexico.274 In the first case, the Commission analyzed this categorization based on the elements detailed in the Inter-American Convention to Prevent and Punish Torture, to wit: i) that it is an act “by which physical and mental pain or suffering is inflicted on a person;” ii) committed “with a purpose;” and iii) “by a public official or by a private person acting at the instigation of the former.” 275 201. For its part, the Inter-American Court has referred to the precedent of Aydin v. Turkey from the European human right system to establish the extent of the damage caused to victims of sexual violence. In that decision, acts of sexual violence against the victim, including rape, were categorized as torture.276 Specifically, in the cases Fernández Ortega et al. and Rosendo Cantú, both against Mexico, sexual violence committed by a state agent was analyzed by the Inter-American Court based on the elements comprising torture, to wit: i) intent, ii) severity of the suffering caused, and iii) the existence of a goal or purpose. 277 202. The Court has also found that some of these elements can be found in cases of sexual violence, especially cases of rape, as it is: [...] an exceedingly traumatic experience that has severe consequences and causes great psychological and physical damage that leaves the victim “physically and emotionally humiliated,” a situation that is difficult to overcome over the passage of time, in contrast to what takes place with other traumatic experiences. It can be derived from this that severe suffering of the victim is inherent to rape, even when there is no evidence of injuries or physical illness. Effectively, not all cases of rape will result in illness or bodily injury. Women who are victims of rape also experience severe psychological and even social damage and consequences.278 203. Under the Istanbul Protocol, a number of acts of sexual violence can be qualified as torture. For example, the Protocol indicates that sexual torture starts at forced nudity, and that a person is most vulnerable when he or she is naked and helpless. Nudity increases the psychological terror of all aspects of torture, as it raises the possibility of mistreatment, rape, or sodomy. Also, verbal threats, insults, and sexual jokes are part of sexual torture because they increase the humiliation and its degrading aspects, all of which are part of the process. For a woman, groping is traumatic in all cases and considered to be torture.279 273 IACHR, Report No. 5/96. Case 10,970. Raquel Martín de Mejía (Peru), March 1, 1996. 274 IACHR, Report No. 53/01. Case 11,565. Ana, Beatriz, and Celia González Pérez. Mexico. April 4, 2001. IACHR, Report No. 5/96. Case 10,970. Raquel Martín de Mejía (Peru), March 1, 1996. Section V. General Considerations, B. Considerations on the merits of the matter. 3. Analysis. 275 276 See: ECHR. Case of Aydin v. Turkey (GC), Judgment of 25 September 1997, App. No. 57/1996/676/866, para. 86. See: Inter-American Court, Case of Rosendo Cantú et al. v. Mexico, Preliminary Objections, Merits, Reparations and Costs, Judgement of August 31, 2010. Series C No. 216, para. 110. 277 278 Inter-American Court, Case of Rosendo Cantú et al. v. Mexico, Preliminary Objections, Merits, Reparations and Costs, Judgement of August 31, 2010. Series C No. 216, para. 114. 279 United Nations, Manual on the Effective Investigation and Documentation of Torture and Other Cruel, Inhuman, or Degrading Treatment or Punishment, Istanbul Protocol, December 2001. Para. 215.