116 REDRESS, Torture in Asia, supra note , at 135 (“[T]his principle is substantially disregarded in practice chiefly due to the police and prosecutors heavily relying upon confessions obtained through torture-related acts.”). 117 PCHR, Torture in Pakistan: A Lawyer's Handbook, at 3 (Undated). 118 For a detailed discussion of the lack of accountability mechanisms, see JPP-Lowenstein, Policing as Torture, supra note 119 PAKISTAN CONST. art. 10 § 2. 120 See, e.g., Human Rights Commission of Pakistan, State of Human Rights in 2014 at 94 (2015), http://hrcpweb.org/hrcpweb/data/HRCP%20Annual%20Report%202014%20-%20English.pdf; U.S. Department of State, Country Reports on Human Rights Practices for 2014: Pakistan, at 13 (2015), http://www.state.gov/j/drl/rls/hrrpt/humanrightsreport/index.htm?year=2014&dlid=236648 (“Some authorities did not observe these limits on detention.”); see also REDRESS, supra note , at 138 (“Constitutional provisions that serve to limit pretrial detention, and set out the right to consult a lawyer upon arrest are undermined by counter-terrorism and security measures, or are simply disregarded in practice by officials.”). 121 JPP-Lowenstein, Policing as Torture, supra note , at 27. 122 Human Rights Commission of Pakistan, State of Human Rights in 2014, supra note , at 94; see also STABILIZING PAKISTAN, supra note ; see also Peter G. Strasser, The Evolving Pakistani Criminal Justice System: A Study of the Raymond Davis Matter, 23 TUL. J. INT'L & COMP. L. 107, 122 (2015). 123 Anti-Terrorism Act of 1997 (XXVI of 1997) § 21(H) (“Notwithstanding any . . . other law . . . the evidence . . . made by the accused during investigation without being compelled, before a police officer not below the rank of a District Superintendent of Police, may be admissible . . . .”). 124 Anti-Terrorism Act of 1997 (XXVI of 1997) § 21(H). 125 FIDH, Slow March, supra note , at 41. 126 For details on Shafqat Hussain's case, please see page 21. 127 For details on Kanizan Bibi's case, please see page 30. 128 Anti-Death Penalty Asia Network, Aftab Bahadur, Pakistan, at 1 (Dec. 2011), https://adpandotnet.files.wordpress.com/2011/11/adpan-appeal-case-pakistan-aftab-bahadur-final.pdf. 129 JPP & Reprieve, Terror on Death Row, supra note , at 18. 130 ICCPR, art. 14(3)(d) (“To be tried in his presence, and to defend himself in person or through legal assistance of his own choosing; to be informed, if he does not have legal assistance, of this right; and to have legal assistance assigned to him, in any case where the interests of justice so require, and without payment by him in any such case if he does not have sufficient means to pay for it.”). 131 General comment No. 32 ¶ 38. 132 General comment No. 32 ¶ 38. 133 Id.; see also Campbell v. Jamaica, U.N. Doc. CCPR/C/44/D/248/1987, IHRL 2371 (UNHRC 1992) (“The Committee recalls its jurisprudence that the State party cannot be held accountable for alleged errors made by a defence lawyer, unless it was or should have been manifest to the judge that the lawyer's behaviour was incompatible with the interests of justice.”). 134 Id. 135 U.S. Department of State, Country Reports on Human Rights Practices for 2015: Pakistan, supra note , at 13 (noting that the government “provided state-funded legal counsel to prisoners facing the death penalty”). 136 FIDH, Slow March, supra note , at 55. 137 Id. 138 For details on Zulfiqar Ali Khan, please see page 24. A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 50