A/HRC/7/3 page 21 Some forms of torture might constitute continuing and permanent violations and in some cases, re-exposure to the stimulus might constitute psychological torture (e.g. when medical expertise indicates that there might be a risk of suicide if a survivor is returned). In the refugee context, even if there is no risk of future persecution, past persecution may nonetheless warrant granting of international protection.81 60. Another gendered aspect of non-refoulement is the argument used with regard to the risk of women to be subjected to FGM, that there is a possibility of “internal flight”, meaning women can return and live safely in another part of the country. In particular in gender-based refugee claims, the lack of State protection in one part of the country is often an indication that the State is also not able or willing to protect the woman or girl in any other part of the country. Furthermore, if the woman or girl relocates, for example from a rural to an urban area to avoid FGM, the protection risks in the place of relocation would have to be carefully assessed.82 C. Justice for women-survivors of torture 1. Access to justice 61. Whereas in many parts of the world women have to overcome a variety of hurdles, including financial and economic constraints, restricted movement, discriminatory laws etc. in order to access justice, victims of sexual violence face particular obstacles at all stages of the criminal justice system. While not widely used, international instruments lay the foundation for special temporary measures to be taken to ensure effective access to justice for women with respect to all forms of violence, including through the enjoyment of fundamental economic and social rights, without which women are less likely to seek justice. In addition, women often do not report sexual violence because of the stigma and sometimes rejection they fear from their family or community. In a recent decision the Committee against Torture held that “It is well-known that the loss of privacy and prospect of humiliation based on revelation alone of the acts concerned may cause both women and men to withhold the fact that they have been subject to rape and/or other forms of sexual abuse until it appears absolutely necessary. Particularly for women, there is the additional fear of shaming and rejection by their partner or family Trafficking and Persons At Risk of Being Trafficked (HCR/GIP/06/07), available at http://www.unhcr.org/cgi-bin/texis/vtx/refworld/rwmain?docid=443679fa4. 81 See UNHCR’s Position on Categories of Persons from Bosnia and Herzegovina in Continued Need of International Protection, September 2001, para. 82. For a discussion of the obstacles to return arising from past persecution, see United Nations High Commissioner for Refugees and United Nations High Commissioner for Human Rights, Daunting Prospects - Minority Women: Obstacles to their Return and Integration (Sarajevo, April 2000), p. 16. 82 For detailed guidance on internal flight, see UNHCR Guidelines on International Protection No. 4 “Internal Flight or Relocation Alternative” within the Context of Article 1A (2) of the 1951 Convention and/or 1967 Protocol relating to the Status of Refugees (HCR/GIP/03/04), available at http://www.unhcr.org/publ/PUBL/3f28d5cd4.pdf.