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Since then, the ECtHR has increasingly resorted to the usage of dignity language in deciphering Article 3. In Selmouni v. France 219 the Court docket ‘reiterates that, in respect of an individual deprived of his liberty, recourse to physical power which has not been made strictly obligatory by his own conduct diminishes human dignity and is in precept an infringement of the precise set forth in Article three’. 220

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