15 often resulted in serious injury of protesters. The use of force by the police under such circumstances was unnecessary and unjustified. Amnesty International has received credible reports that, after inflicting injuries on protesters during arrest, police have denied them access to medical care as a form of punishment.(66) Amnesty International believes that the government of Zimbabwe has failed to protect women human rights defenders engaged in peaceful protest from the use of excessive force by police. In situations where law enforcement officials resort to force, their conduct must be guided by standards respectful of the human rights of individuals. Such standards must be enforceable against officials who break them. Authoritative interpretations on the use of force by law enforcement officials clearly recognize that force can only be used where it is strictly necessary and to the extent required by the situation.(67) In the commentary on Article 3 of the Code of Conduct for Law Enforcement Officials, it is pointed out that: "National law ordinarily restricts the use of force by law enforcement officials in accordance with a principle of proportionality. It is to be understood that such national principles of proportionality are to be respected in the interpretation of this provision. In no case should this provision be interpreted to authorize the use of force which is disproportionate to the legitimate objective to be achieved." The Basic Principles on the Use of Force and Firearms by Law Enforcement Officials deal with the policing of unlawful assemblies.(68) Principle 12 states: "As everyone is allowed to participate in lawful and peaceful assemblies, in accordance with the principles embodied in the Universal Declaration of Human Rights and the International Covenant on Civil and Political Rights, governments and law enforcement agencies and officials shall recognize that force and firearms may be used only in accordance with principles 13 and 14." Principle 13 reads: "In the dispersal of assemblies that are unlawful but non-violent, law enforcement officials shall avoid the use of force or, where that is not practicable, shall restrict such force to the minimum extent necessary." The adverse differential treatment of human rights organizations, trade unions and opposition parties by police is evident in the way in which lawyers representing human rights defenders are treated. Women human rights defenders are denied access to lawyers while in police custody. Lawyers interviewed by Amnesty International indicated that representing human rights defenders in custody entailed a process of negotiation with the police which they compared with hostage negotiation.(69) Lawyers have resorted to sitins at police stations, first to negotiate access to the clients, then to negotiate for access to food, water and medical care for the detainees. They also have to negotiate for the release of their clients – often a long process that can extend for up to five days. Police are often spiteful and abusive to lawyers and even threaten to arrest and detain them.(70) Amnesty is deeply concerned that police in Zimbabwe flagrantly violate the rights of human rights defenders to have access to lawyers. The UN Basic Principles on the Role of Lawyers Article 8 states the right of "all arrested, detained or imprisoned persons" to be provided with "adequate opportunities, time and facilities to be visited by and to communicate and consult with a lawyer, without delay, interception or censorship and in full confidentiality." Torture, cruel, inhuman and degrading treatment Amnesty International is deeply concerned that, in most instances where women human rights defenders and their male counterparts are arrested and detained, they have been subjected to torture, inhuman and degrading treatment. The beating, torture, as well as sexist verbal attacks and other forms of inhuman and degrading treatment of women human rights defenders while in police custody, violates Section 15 (1) of the Constitution of Zimbabwe, which guarantees the right to be protected from torture, inhuman or degrading punishment. Although Zimbabwe is not a state party to the UN Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (CAT), it has ratified the ICCPR and the African Charter which also outlaw torture and other cruel, inhuman or degrading treatment or punishment. Article 5 of the African Charter and Article 7 of the ICCPR unequivocally prohibit the practice of torture. The CAT defines Torture as: "Any act by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person for such purposes as obtaining from him or a third person information or a confession, punishing him for an act he or a third person has committed or is suspected of having committed, or intimidating or coercing him or a third person, or for any reason based on discrimination of any kind, when such pain or suffering is inflicted by or at the instigation of or with the consent or