A/HRC/13/42* page 19 days constitutes a violation of article 10 of the Covenant.25 Incommunicado detention includes situations where a detainee’s family is informed that the person is “safe”, without disclosure of the location or nature of the person’s detention. 32. The ill-treatment threshold may be reached when the period of incommunicado detention is prolonged and additional circumstances prevail. For example, in the case of Polay Campos v. Peru,26 the Human Rights Committee found a violation of both articles 727 and 10 of the Covenant as the detained submitter of the complaint had not been allowed to speak or to write to anyone, including legal representatives, for nine months, and had been kept in an unlit cell for 23 and a half hours a day in freezing temperatures. It held that the incommunicado detention to which the author was subjected for longer than eight months constituted inhuman and degrading treatment.28 Similarly, the Inter-American Court of Human Rights has stated that prolonged isolation and deprivation of communications are in themselves cruel and inhuman treatment, even if it is not known what has actually happened during the prolonged isolation of the particular individual.29 In El-Megreisi v. Libyan Arab Jamahiriya,30 the Human Rights Committee found that the Government of the Libyan Arab Jamahiriya had violated articles 10, paragraphs 1 and 7 of the Covenant by detaining an individual for six years, the last three of which incommunicado and in an unknown location, which in the view of the Committee reached the torture threshold. 33. The practice of secret detention, as reflected by the cases covered in the present study, also confirms that incommunicado detention, including secret detention, facilitates the commission of acts of torture. 34. The General Assembly, in its resolution 60/148, and the Human Rights Council, in its resolution 8/8, both state that prolonged incommunicado detention or detention in secret places may facilitate the perpetration of torture and other cruel, inhuman or degrading treatment or 25 Lucía Arzuaga Gilboa v. Uruguay, communication No. 147/1983 (CCPR/C/OP/2), para. 14. 26 Polay Campos v. Peru, communication No 577/1994(CCPR/C/61/D/577/1994), para. 8.4. 27 “No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment.” 28 Steve Shaw v. Jamaica, communication No. 704/1996 (CCPR/C/62/D/704/1996), paras. 2.5 and 7.1, taking into account that the prisoner during his period of pre-trial detention was further confined to a cell, which was grossly overcrowded, and had to sleep on a wet concrete floor. 29 Velasquez Rodriguez case, judgement of 29 July 1988, Inter-American Court of Human Rights, (Ser. C); No. 4 (1988), para.187. 30 Communication No. 440/1990 (CCPR/C/50/D/440/1990), para. 5.4.