On May 5, the European Court of Human Rights passed judgment in the case Arratibel Garciandia v. Spain, ruling that Spain violated Article 3 of the Convention by not having adequately investigated complaints of torture and abuse which the plaintiff claims to have suffered while in being held incommunicado. The Court of Human Rights, as on other occasions, reiterates that the Spanish practice of incommunicado detention lacks sufficient safeguards against torture, and joins other organizations in recommending that this practice be eradicated.