96 JPP & Reprieve, Terror on Death Row, supra note , at 11. 97 Justice Project Pakistan & Reprieve, Juveniles on Pakistan's Death Row, at 6-7 (2015), http://tbinternet.ohchr.org/Treaties/CRC/Shared%20Documents/PAK/INT_CRC_NGO_PAK_21444_E.pdf. 98 Jon Boone, Pakistan Hangs Shafqat Hussain Despite Claim He Was a Child at Time of Crime, GUARDIAN (Aug. 4, 2015), https://www.theguardian.com/world/2015/aug/04/pakistan-hangs-shafqat-hussain-claim-child-crime. 99 The prohibition of torture is non-derogable. Article 1 of the Convention Against Torture (CAT) explicitly prohibits “any act by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession.” Convention Against Torture and Other Cruel, Inhuman, or Degrading Treatment or Punishment, Dec. 10, 1984, 1465 U.N.T.S. 85, art. 1(1) [hereinafter CAT]. This prohibition is enshrined in the ICCPR. ICCPR, art. 7 (“No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment. . . .”). 100 CAT, art 2(1). 101 Gridin v. Russian Federation, ¶ 8.5, U.N. Doc. CCPR/C/69/D/770/1997 (2000). 102 Human Rights Comm., General Comment No. 32, supra note , ¶ 38. 103 ICCPR, art. 14(g). 104 Human Rights Comm., General Comment No. 32, supra note , ¶ 41. 105 Othman (Abu Qatada) v. United Kingdom, App. No. 8139/09, 2012 Eur. Ct. H.R. 56. 106 After a 2011 visit to Pakistan, the Special Rapporteur on torture and cruel, inhuman or degrading treatment or punishment concluded that “[t]orture, including rape, and similar cruel, inhuman or degrading treatment are rife in Pakistan,” and that it is “most frequently used to secure confessions or information relating to suspected crimes.” U.N. Commission on Human Rights, E/CN.4/1997/7/Add.2 (1996). The International Federation of Human Rights further reports how “torture is routinely used to extract information or confessions from suspects, and illegal detentions are common,” and quotes a police superintendent as affirming that “in effect, the police has complete and unchecked powers. And the lack of modern investigative techniques means that we are 'forced' to torture to secure confessions.” FIDH, Slow March, supra note , at 47. 107 FIDH, Slow March, supra note , at 47. 108 JPP-Lowenstein, Policing as Torture, supra note , at 1. 109 Id. at 5. 110 See International Crisis Group, Reforming Pakistan's Police, Asia Report N°157, at 1-4, 9, 25 (July 14, 2008), http://www.genocidewatch.org/images/Pakistan_08_07_14_Reforming_Pakistan_s_Police.pdf; STABILIZING PAKISTAN, supra note , at 36; Sikander Ahmed Shah, et al., Police Order 2002: Police Reforms in Pakistan, in DEVOLUTION AND GOVERNANCE: REFORMS IN PAKISTAN 221 (Syed Mubashir Ali & Muhammad Amjad Saqib eds., 2008). 111 While the Torture and Custodial Death (Prevention and Punishment) Bill has been pending in National Assembly since it was first introduced in 2012, the Bill has been allowed to lapse several times with no demonstrable political will pushing for its enactment. The National Action Plan of Human Rights had set July of 2016 as the deadline for the enactment of this law. U.S. Department of State, Country Reports on Human Rights Practices for 2015: Pakistan, at 6 (2016), http://www.state.gov/j/drl/rls/hrrpt/humanrightsreport/index.htm?year=2015&dlid=252973. 112 Asian Human Rights Commission, AHRC Special Report:Torture Situation in Pakistan 1, 2(June 26, 2010), http://www.humanrights.asia/resources/special-reports/AHRC-SPR-001-2010-01/. For a general discussion of the difficulties of police reform, see Shoaib Suddle, Obstacles to Reform, inSTABILIZING PAKISTAN, supra note , at 36. 113 REDRESS, Torture in Asia: The Law and Practice, at 138 (Oct. 2013), http://www.refworld.org/docid/52fa25204.html. 114 Hassan Abbas, Internal Security Issues in Pakistan, supra note , at 150. 115 PAK. CODE CRIM. PROC., § 164 (“Any magistrate . . . may, if he is not a police-officer, record any statement or confession made to him . . . .”) (emphasis added). A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 49