Detainee monitoring may also mitigate the risk of abuse. 157 Though monitoring alone is not sufficient to meet states’ non-refoulement obligations, it has been shown to be effective when monitors are independent, and have full, unfettered access to detention facilities and detainees, as well as private, confidential interviews with detainees. Trained forensic and medical experts have also been shown to be critical elements of a detainee monitoring regime in order to properly evaluate and identify any physical evidence of abuse. 158 Because jails in Pakistan are under the exclusive administrative control of provincial governments, access to detainees by independent monitors can vary according to province. Where such access is authorized, as it is in Sindh province, monitors specialized in detecting signs of torture from NGOs such as the ICRC or the Human Rights Commission of Pakistan (HRCP) may be more easily permitted unfettered and confidential access to detainees. Such organizations could be approached to engage in or oversee monitoring of transferred detainees. In provinces where access is more restricted— Punjab for example—arrangements should be made to ensure effective and reliable monitoring mechanism are in place. Pakistani law also permits provincial governments to authorize judges, doctors, psychiatrists and national and provincial lawmakers regular access to jails, enabling Pakistan to put in place yet another layer of monitoring and transparency. 159 Authorized individuals have the right to hold confidential interviews with detainees. 160 Pakistani law is silent on whether visits can be held without prior notice. A specially tasked, delegation of lawmakers, doctors and judges could also engage in detainee monitoring or complement systematic monitoring by independent bodies and ensure that detainees’ rights are respected. Pakistani government officials could ensure that such monitors had confidential, unfettered access to detainees. Notifications of transfer from the DFIP to Pakistan to relatives of detainees, legal counsel and third party monitors may also significantly mitigate the risk of torture. Evidence shows that detainees held in incommunicado detention are at much greater risk of torture. 161 In the past, the U.S. and Pakistani governments have generally failed to provide such notification to family members or legal counsel. court-3; “Missing persons cases: a dozen more shifted to internment centres”, Dawn, 26 April, 2013, http://x.dawn.com/2013/04/26/missing-person-cases-a-dozen-more-shifted-to-internment-centres/; Hasnaat Malik, “Missing persons’ issue might take decades to solve: AGP”, Daily Times, 2 July, 2013, http://www.dailytimes.com.pk/default.asp?page=2013%5C07%5C02%5Cstory_2-7-2013_pg7_1 157 See Agiza at 13.4; Alzery at 11.5; Othman at 77 for a description of the value of detainee monitoring in mitigating torture risks. 158 Ibid. 159 Rules 913, 917 Pakistan Prison Rules. 160 Rule 919, 924 Pakistan Prison Rules. 161 Human Rights Committee, General Comment 20, Article 7 (Forty-fourth session, 1992), http://www.unhchr.ch/tbs/doc.nsf/0/6924291970754969c12563ed004c8ae5, para. 11; “General recommendations of the Special Rapporteur on torture”, http://www.ohchr.org/Documents/Issues/SRTorture/recommendations.pdf, p. 2; “Joint study on global practices in relation to secret detention in the context of countering terrorism of the Special Rapporteur on the Promotion and Protection of Human Rights and Fundamental Freedoms while Countering Terrorism, Martin Scheinin; the Special Rapporteur on Torture and other Cruel, Inhuman or Degrading treatment or Punishment, Manfred Nowak; the Working Group on Arbitrary Detention represented by its Vice-Chair, Shaheen Sardar Ali; and the Working Group on Enforced or Involuntary Disappearances represented by its Chair, Jeremy Sarkin”, A/HRC/13/42, 19 February, 2010, http://www2.ohchr.org/english/bodies/hrcouncil/docs/13session/A-HRC-13-42.pdf, ps. 19-20, paras. 33-34; 41