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d shaving or shackling could act as a bar to extradition because the Court had found these forms of ill-treatment to be in breach of Article 3 (see Yankov v. Bulgaria, no. 39084/97, §§ 114- 121, ECHR 2003-XII (extracts); and Henaf v. France, no. 65436/01, §§ 45- 89, ECHR 2003-XI). 163. The Government d
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