3 by extraditing or deporting an individual to a country where upon their return might be subject to torture, inhuman or degrading treatment or punishment. In Chahal v United Kingdom [1996] the United Kingdom had initiated deportation proceedings, for national security reasons, on an Indian citizen. Mr Chahal had associations with the Sikh separatist movement and there was substantial evidence that upon his return to India, he would be subjected to treatment contrary to Article 3. On this basis, the ECtHR held that, as the assurances of Mr Chahal's safety from the Indian government were not convincing, his deportation would violate Article 3. In Soering v United Kingdom [1989] the UK government attempted to extradite a German national, who was wanted by the state of Virginia for the murder of his partner's parents, to the USA. It was held that upon his return, Mr Soering would have been subject to inhuman and degrading treatment or punishment in the form of the 'death row phenomenon', whereby a person sentenced to capital punishment suffers years of mental torment awaiting their execution. The UK was accordingly found in breach of Article 3. Additional protections All parties to the ECHR are also party to the United Nations Convention against Torture and other cruel or inhuman, degrading treatment or punishment (1987). All members of the Council of Europe are also party to the European Convention for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (1987). Parties may have domestic laws criminalising torture, distinct from general crimes against the person. For example in the UK, s. 134 of the Criminal Justice Act 1988 makes it a criminal offence for a public officer or professional acting in an official capacity to commit torture or inflict severe pain or suffering on another. Other cases Life imprisonment On 9 July 2013, UK prisoner Jeremy Bamber won an appeal to the European Court of Human Rights that whole life imprisonment (with no chance of parole) was in contravention of Article 3 of the European Convention on Human Rights. The Grand Chamber voted overwhelmingly in favour of the decision by 16–1, meaning that the UK government was forced to review 49 instances of whole life sentences. Ataun Rojo v Spain In this case, which ran jointly with Etxebarria Caballero v Spain in 2014, the court held unanimously that there had been "a violation of Article 3 (prohibition of