as defined in the Convention,154 and not to “cruel, inhuman or degrading treatment or punishment”. Regionally, Greece is bound by the 1950 European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR). Article 3 of the ECHR prohibits “torture or inhuman or degrading treatment” – a different formulation than either the ICCPR or the CAT. The European Court of Human Rights jurisprudence is clear that this carries a nonrefoulement obligation not to expose an individual to a “real risk” of that treatment.155 As documented in this report, Turkey’s treatment of migrants returned from Greece in the Tunca detention center at Edirne is inhuman and degrading: Conditions of detention are appallingly poor, particularly with respect to overcrowding and sanitation; the duration of detention is indefinite; and there are reports of guards mistreating detainees. Although Human Rights Watch received reports of inhuman and degrading treatment at other detention facilities in Turkey, we cannot definitively conclude that those conditions amount to such treatment as we did not visit other facilities. However, the use of indefinite administrative detention to coerce migrants to self deport, combined with these other factors, suggests that Turkey’s breach of its obligations is wider than the Tunca detention facility at Edirne. In any case, Greece remains in breach of its obligations under the ECHR in that there is a real risk that the Turkish authorities will detain returned migrants at Tunca. This real risk applies particularly to those migrants returned at the Evros River. The risk may also exist for migrants pushed back at sea if the conditions at other Turkish migration detention centers prove to be as degrading and inhuman as the conditions Human Rights Watch found at Edirne. 154 Article 3 of CAT provides the non-refoulement obligation. Article 1 defines “torture”. 155 See Soering v United Kingdom 98 ILR 270; Cruz Varas v. Sweden, 108 ILR 283, Vilvarajah v. United Kingdom, 108 ILR 321; Chahal v. United Kingdom, 108 ILR 385; and T.I. v United Kingdom Application No.43844/98, Decision as to Admissibility, March 7, 2000. 67 Human Rights Watch November 2008