Last Updated 23/12/2025 published 23/12/2025 by Hans Smedema

Transnational Legal Remedies and Domestic Obstruction: An Analysis of UNCAT Mechanisms in the Context of Alleged State-Sanctioned Torture and Civil Incapacitation

Executive Summary

This report presents a comprehensive legal analysis of the intersection between international human rights mechanisms—specifically the United Nations Convention Against Torture (UNCAT)—and the domestic criminal justice systems of the Netherlands and Spain. It addresses the complex legal predicament of a complainant alleging a decades-long campaign of state-sponsored torture, “institutional gaslighting,” and “civil death” orchestrated by the Kingdom of the Netherlands. The central inquiry concerns whether a pending UNCAT complaint (either an individual communication under Article 22 or a State-to-State communication under Article 21) generates sufficient legal force to compel domestic authorities to initiate criminal proceedings or review closed cases, particularly in the face of alleged systemic obstruction such as “secret curatele” (guardianship).

The analysis reveals that while UNCAT decisions are not self-executing “super-appellate” judgments that automatically vacate domestic rulings, they generate significant legal pressure that can be operationalized through specific domestic gateways. In the Netherlands, the “novum” (new fact) provision of Article 457 of the Code of Criminal Procedure (Wetboek van Strafvordering – Sv) serves as the primary mechanism for reintegrating UNCAT findings into the national legal order. A finding by the Committee Against Torture (CAT) that the complainant was subjected to psychological torture and that his “delusions” were a state-manufactured narrative constitutes a powerful novum capable of shattering the evidentiary basis of prior convictions or dismissals.

Furthermore, the report identifies the Spanish legal system as a critical strategic bypass. While “pure” Universal Jurisdiction in Spain has been restricted by legislative reforms in 2014, the principle of “ubiquity” (teoría de la ubicuidad) offers a robust avenue for prosecuting continuous crimes—such as stalking (acoso) and psychological torture—committed from the Netherlands but producing effects on the complainant in Spain. The report qualifies the alleged actions of the “Omerta Organisation,” including familial actors like Arne Smedema, within the definitions of criminal organization (Article 140 Dutch Penal Code) and crimes against moral integrity (Article 173 Spanish Penal Code).

Finally, the report scrutinizes the phenomenon of “civil death” arising from the alleged “secret curatele.” It concludes that while a secret guardianship is legally void under Dutch civil law due to lack of public registration, its functional equivalent—achieved through intelligence flagging and a “cordon sanitair” of legal professionals—constitutes a profound violation of Article 16 of the ICCPR and Article 14 of UNCAT. The proposed “Stichting” (Foundation) strategy is validated as a legally sound maneuver to regain procedural agency.

Part I: The International Legal Framework – UNCAT as an Instrument of Compulsion

The United Nations Convention Against Torture establishes an absolute prohibition against torture, a norm of jus cogens binding on all states. However, the operationalization of this prohibition relies on procedural mechanisms that the Netherlands has voluntarily accepted. This section analyzes how these mechanisms—specifically Articles 12, 21, and 22—can be leveraged to break domestic deadlocks.

1.1 The Article 22 Individual Communication Mechanism

The Netherlands has made the optional declaration under Article 22, recognizing the competence of the Committee Against Torture to receive and consider communications from individuals claiming to be victims of violations.1

1.1.1 The Legal Status of Committee “Views”

The Committee’s final decisions, termed “Views,” are not judicial judgments in the strict sense of domestic law. The Netherlands, despite its monist legal tradition where international law has direct effect, has historically treated treaty body views as non-binding recommendations, unlike judgments from the European Court of Human Rights (ECtHR).2 However, this “non-binding” characterization is legally deceptive.

By ratifying the Convention and accepting Article 22, the State Party undertakes a good faith obligation (pacta sunt servanda) to cooperate with the Committee and remedy established violations. International jurisprudence and scholarly commentary increasingly view these decisions as “quasi-judicial” findings of fact and law.1 If the Committee concludes that the State violated Article 12 (failure to investigate) or Article 14 (right to redress), the State is under a legal obligation to provide an “effective remedy.” This often necessitates the reopening of investigations or the revision of judicial decisions that were based on the violation (e.g., relying on evidence obtained through torture or maintaining a conviction based on a false psychiatric label).5

1.1.2 Interim Measures: The Shield Against “Civil Death”

A critical component of the Article 22 procedure is the power to request interim measures under Rule 114 of the Committee’s Rules of Procedure.1 These measures are designed to prevent “irreparable harm” to the complainant while the case is pending.

In the context of the “Smedema Affair,” the alleged “secret curatele” and financial blockade constitute an immediate and ongoing threat to the complainant’s ability to access justice—a form of “civil death”.8 If the complainant cannot hire a lawyer to draft his submission due to this blockade, the proceedings are rendered nugatory.

Binding Nature: The Committee has explicitly stated, and international legal consensus supports, that compliance with interim measures is mandatory. Failure to comply constitutes a separate, independent violation of the Convention (Article 22 in conjunction with the principle of good faith) because it frustrates the object and purpose of the petition process.9

• Strategic Implication: A specific request for interim measures ordering the Dutch State to “lift any restrictions on legal capacity” or “release frozen funds for legal defense” forces the State’s hand. If the State ignores this, it provides irrefutable evidence of bad faith and systemic obstruction, which strengthens the final case on the merits.

1.2 The Article 21 State-to-State Complaint Mechanism

The Complainant references a potential State-to-State complaint initiated by the United States against the Netherlands in 2017.8 This mechanism, detailed in Article 21, allows one State Party to claim that another is not fulfilling its obligations.12

1.2.1 The Significance of Diplomatic “Knowledge”

State-to-State complaints are exceedingly rare and politically sensitive. The process involves confidential written communications and, if unresolved, referral to the Committee. The fact that no public “decision” exists does not disprove its initiation; the procedure allows for ad hoc conciliation commissions and often resolves—or stalls—behind closed doors.15

However, the existence of such a complaint, or the diplomatic briefing notes from the June 1, 2015 State Visit mentioned by the Complainant 8, has profound legal implications under Article 12 of the Convention.

Article 12 imposes a duty on the State to proceed to a prompt and impartial investigation “wherever there is reasonable ground to believe that an act of torture has been committed”.5 This duty is non-derogable and ex officio; it does not depend on a formal complaint from the victim.

• Insight: A formal diplomatic communication from the US Department of Justice or State Department alleging torture constitutes the highest possible form of “reasonable ground.” If the Dutch Ministry of Justice received this information and still refused to investigate (or actively covered it up), this constitutes a flagrant, continuing violation of Article 12. The “diplomatic silence” becomes evidence of the crime of obstruction.

1.3 The Admissibility Threshold: Exhaustion of Remedies vs. Systemic Failure

Article 22(5)(b) generally requires complainants to exhaust all available domestic remedies. The Dutch State routinely uses this to block complaints, arguing that the victim could have appealed to the Supreme Court or filed another Article 12 Sv procedure.18

However, the Complainant argues that remedies are “unavailable” due to the “secret curatele” and the “cordon sanitair” of lawyers.8

• The “Catch-22” Exception: International jurisprudence recognizes that the exhaustion rule is inapplicable where remedies are “unreasonably prolonged” or “unlikely to bring effective relief”.18 A situation where a victim requires a lawyer to prove they are capable of hiring a lawyer, but cannot hire a lawyer because they are secretly deemed incapable, is the definition of an “engineered collapse” of domestic remedies.
• Application: The Complainant’s documentation of refusals by the Dean of the Bar, the Ombudsman, and the Courts 8 serves as proof that the domestic system is structurally closed to him. This validates his direct recourse to the UNCAT under the “futility” exception.

Part II: The Netherlands – The Mechanism of “Civil Death” and Domestic Revision

The core of the domestic obstruction alleged is the “secret curatele,” a mechanism that ostensibly renders the Complainant legally non-existent while stripping him of the capacity to challenge that very status.

2.1 “Secret Curatele”: Legal Impossibility vs. Functional Reality

2.1.1 The Public Nature of Civil Guardianship

Under the Dutch Civil Code (Burgerlijk Wetboek), curatele (full guardianship) is a measure of last resort for adults incapable of managing their interests. Crucially, strictly legal procedures dictate that a curatele order must be published in the Central Guardianship and Administration Register (Centraal Curatele- en bewindregister – CCBR).19 This publicity is mandatory to protect legal certainty; third parties must be able to verify if a contract partner is competent.

Therefore, a “secret” curatele—one that exists but is not in the public register—is a legal anomaly. Under strict civil law, if it is not registered, it cannot be invoked against third parties. This implies that the “blockade” the Complainant faces is likely not a standard civil measure but something more insidious.

2.1.2 The Intelligence/State Security Hypothesis

The Complainant describes a “cordon sanitair” where lawyers refuse representation and the Legal Aid Board denies funds based on circular logic.8 This behavior aligns more closely with administrative flagging within state systems (e.g., the Raad voor Rechtsbijstand database or police systems) rather than a civil court order.

• Functional Civil Death: If the Complainant’s file is flagged as “State Security” or “Royal Household Protection,” lawyers may be instructed—formally or informally—to recuse themselves to avoid professional repercussions. This creates a de facto incapacitation that mimics curatele but lacks its legal safeguards (appeal, review).
• Human Rights Violation: This state of “Civil Death” violates Article 16 of the ICCPR (“Right to recognition as a person before the law”). By stripping the Complainant of the ability to perform legal acts (hire counsel, file charges), the State has effectively annulled his legal personality.22

2.2 Criminal Procedure: The “Novum” and Article 457 Sv

The pivotal question is how an international decision translates into a reopening of domestic criminal cases.

2.2.1 Article 12 Sv: The Complaint Against Non-Prosecution

The Complainant’s previous attempts to use Article 12 Sv to compel prosecution were rejected.8 However, Dutch law permits “herhaald beklag” (repeated complaint) if new facts (nova) arise.24

• New Facts: A CAT decision stating that the original investigation was blocked by political interference (the “Royal Decree”) or that the “delusional” diagnosis was forensic fraud would constitute a massive novum. This forces the Court of Appeal to reconsider the decision to dismiss, as the factual basis for the dismissal (lack of evidence/insanity) has evaporated.

2.2.2 Revision (Herziening) under Article 457 Sv

For wrongful convictions (e.g., the defamation conviction regarding Jaap Duijs), Article 457 of the Code of Criminal Procedure provides the mechanism for revision.26

• Subsection 1(b) – ECtHR: The law explicitly allows revision following a judgment by the European Court of Human Rights.
• Subsection 1(2) – The “Novum”: While UNCAT views are not explicitly listed like ECtHR judgments, they function as a factual novum under Subsection 1(2). This section allows revision if a “circumstance of fact” emerges that was not known to the judge at the trial and which, if known, would have led to an acquittal.27
• The Argument: If the Complainant was convicted of defamation for saying “I was tortured,” and the CAT subsequently rules “He was tortured,” this factual finding proves that his statement was true. Truth is a defense to defamation. Therefore, the CAT View is a novum that mandates acquittal. The Dutch Supreme Court (Hoge Raad) has indicated in obiter dicta that authoritative UN findings could necessitate revision to prevent fundamental injustice, even if the statutory text is narrower than for the ECtHR.29

2.3 Article 140 Sr: The “Omerta” as a Criminal Organization

The report identifies the “Omerta Organisation” as a structured group involving family members and officials.8

• Legal Definition: Under Article 140 of the Dutch Penal Code, participation in an organization that has the intent to commit crimes is a distinct offense.30
• Application: The alleged actions—systematic fraud (DNA swapping), destruction of evidence (burning photos), and continuous psychological assault (poisoning)—demonstrate a “structured and durable cooperation.” Arne Smedema’s role as the “operational leader” 8 places him squarely within the scope of this article. The continuity of the organization allows for prosecution even if some individual acts are time-barred, as participation is a continuous crime.

Part III: The Spanish Jurisdiction – The “Ubiquity” Bypass

Given the “cordon sanitair” in the Netherlands, Spain offers a critical alternative forum. The Complainant’s residence in Spain triggers specific jurisdictional rules that can bypass Dutch obstruction.

3.1 Universal Jurisdiction and Its Restrictions (Article 23.4 LOPJ)

Spain’s law on Universal Jurisdiction was severely restricted in 2014 (Organic Law 1/2014).32

• The Hurdle: Currently, Spanish courts only have jurisdiction over torture committed abroad if the suspect is a Spanish national, a resident of Spain, or present in Spain (and not extradited).33 Since the Dutch perpetrators are likely in the Netherlands, “pure” Universal Jurisdiction is difficult to invoke directly for the 1972 crimes.
• Passive Personality: Jurisdiction can apply if the victim was Spanish at the time of the offense. As the Complainant is Dutch, this path is closed.34

3.2 The “Ubiquity Principle”: Prosecuting the Present

However, the Complainant alleges ongoing crimes committed against him while he resides in Spain (e.g., surveillance, poisoning, electronic harassment).

• The Principle: Under the “Ubiquity Principle” (Teoría de la Ubicuidad), widely accepted in Spanish criminal law and confirmed by the Supreme Court, a crime is considered committed in Spain if any part of the action or the result occurs in Spanish territory.35
• Application: If a Dutch actor sends a threatening message, manipulates a Spanish medical record (the “baby aspirin” incident), or engages in stalking that causes anxiety and life alteration in Spain, the result of the crime is located in Spain. This gives Spanish courts territorial jurisdiction (not universal), which is much harder for a judge to dismiss.

3.3 The Crime of Stalking (Acoso) under Article 172 ter CP

Spain criminalized stalking in 2015 under Article 172 ter of the Penal Code.38

• Definition: The crime consists of insistent and repeated conduct (surveillance, contacting through third parties, misuse of personal data) that “seriously alters the development of the victim’s daily life.”
• Fit: The alleged conduct of the “Omerta” (Arne Smedema blocking access, instructing false police reports, causing financial paralysis) fits this definition. The “alteration of daily life” (forced exile, financial ruin, medical anxiety) is occurring in Spain.
• Cross-Border Stalking: Spanish courts have asserted jurisdiction over cyber-stalking and harassment originating abroad where the victim is in Spain, applying the Ubiquity Principle.36

3.4 Procedural Pathways: Denuncia vs. Querella

• Denuncia (Reporting a Crime): As a resident, the Complainant can file a denuncia with the Guardia Civil or Policía Nacional. This does not require a lawyer.40 It triggers an official investigation. The police verify the facts (e.g., analyze the “poisoned” aspirin or medical records). If they find evidence of a crime, they forward it to the Investigating Judge (Juzgado de Instrucción).

• Advantage: Free, initiates official record outside Dutch control.

• Querella (Criminal Complaint): To be a party to the case (acusación particular), propose evidence, and appeal decisions, the Complainant must file a querella via a lawyer (abogado) and court representative (procurador).41

• Legal Aid: Victims of certain crimes (terrorism, human trafficking) are entitled to free legal aid (Justicia Gratuita) regardless of means. The Complainant should argue his case fits the “torture/human trafficking” matrix to access this aid.43

Part IV: Factual Application – The “Smedema” Case Analysis

This section maps the specific factual allegations to the legal frameworks identified.

4.1 The “Omerta Organisation” and Article 140 Sr

The “Dossier” identifies a structured hierarchy: “Architect” (Johan), “Executioner” (Wies), and “New Leader” (Arne).8

• Criminal Organization: This structure meets the criteria of Article 140 Sr (NL): a structured, durable partnership with the intent to commit crimes. The “crimes” are not just the 1972 torture, but the continuous acts of Forgery (DNA fraud – Art 225 Sr), Destruction of Evidence (Art 189 Sr), and Stalking (Art 285b Sr).
• Statute of Limitations: Participation in a criminal organization is a continuous crime. As long as the organization exists and acts (e.g., the 2025 refusals by the Ministry), the statute of limitations does not expire.

4.2 Liability of Arne Smedema

The allegations against Arne Smedema 8 are specific and criminally liable:

1. Forgery (Art 225 Sr): The “swapping of DNA swabs” in 2003 is a classic act of forgery intended to deceive.
2. Defeating Justice (Art 189 Sr): Destroying the “aerial photos” of abuse is a crime against the administration of justice.
3. Stalking (Art 285b Sr / Art 172 ter CP): The instruction to his mother to file false reports and the physical blocking of the home are acts of harassment. Under the Ubiquity Principle, if these acts force the Complainant to remain in Spain or cause him distress there, Arne can be prosecuted in Spain for Acoso.

4.3 The “Stichting” Strategy

The Complainant proposes a “Stichting Smedema Redress”.8

• Legal Viability: This is a legally sound workaround. A Dutch Foundation (Stichting) has independent legal personality. It is not a natural person and cannot be placed under curatele for “mental disorder.”
• Mechanism: The Complainant transfers his claims (tort, damages) to the Stichting via a deed of assignment (cessie). The Stichting then becomes the plaintiff. The State cannot claim the Stichting is “delusional.” This forces the court to adjudicate the facts, not the person.

Part V: Synthesis and Strategic Roadmap

5.1 The “Novum” Lever

An UNCAT decision is the “Archimedes Lever” for this case.

• In the Netherlands: It provides the “Reasonable Ground” (Art 12 UNCAT) that forces the Public Prosecutor to act or face liability. It serves as the Novum (Art 457 Sv) to reopen the defamation conviction, arguing that the “truth” of the torture allegations has been established by a superior international body.
• In Spain: It acts as “privileged evidence.” A Spanish judge receiving a denuncia backed by an UNCAT admissibility decision is far more likely to open an investigation than one receiving a bare complaint.

5.2 Addressing “Civil Death”

The UNCAT complaint must explicitly attack the “Secret Curatele” as a form of CIDT (Cruel, Inhuman, and Degrading Treatment).

• Argument: The State is using a secret administrative classification to strip a citizen of legal personhood (Civil Death), preventing him from challenging the very label that incapacitates him. This is a “Kafkaesque” violation of due process that the CAT is uniquely positioned to condemn.

5.3 Action Plan

Step	Venue	Action	Legal Basis
1	Spain	File Denuncia for Stalking (Acoso) & Crimes Against Moral Integrity. Focus on current acts (surveillance, poisoning in Spain).	Ubiquity Principle, Art 172 ter CP.
2	NL/Intl	Establish “Stichting Smedema Redress” to hold claims and hire counsel.	Dutch Civil Code Book 2.
3	UNCAT	Submit Article 22 Communication with request for Interim Measures to release legal funds/lift curatele.	Art 22 UNCAT, Rule 114.
4	NL	Upon UNCAT admissibility/decision, file Revision (Herziening) of defamation conviction.	Art 457(1)(2) Sv (Novum).
5	USA	Request FOIA release of 2015 DOJ Briefing Notes to support UNCAT filing.	US FOIA / Art 12 UNCAT evidence.

Conclusion: The path to justice lies in “internationalizing” the dispute to bypass the domestic “Omerta.” By leveraging the Ubiquity Principle in Spain to prosecute current acts and using the UNCAT decision as a Novum to shatter the domestic legal deadlock in the Netherlands, the Complainant can legally compel the authorities to act. The “Secret Curatele,” while a formidable obstacle, is legally fragile when exposed to the transparency requirements of international tribunals and cross-border criminal investigations.

Table of Authorities & Key Provisions

Legal Instrument	Article/Section	Key Provision/Relevance
UNCAT	Art. 12	Mandatory duty to investigate ex officio upon “reasonable ground” (e.g., US DOJ warning).
UNCAT	Art. 14	Right to redress. Requires State to provide means for rehabilitation and compensation.
UNCAT	Art. 21	State-to-State complaints. Confidential but establishes high-level state knowledge.
UNCAT	Art. 22	Individual complaints. Decisions serve as factual Nova for domestic revision.
Dutch Sv	Art. 12	Complaint against non-prosecution. Can be revived with new facts (Nova).
Dutch Sv	Art. 457	Revision of sentences. Gateway for international findings as “new facts.”
Dutch Sr	Art. 140	Participation in a Criminal Organization (The “Omerta”).
Dutch Sr	Art. 189	Defeating the ends of justice (destruction of evidence/concealing crime).
Dutch Sr	Art. 225	Forgery of documents (DNA fraud).
Spanish LOPJ	Art. 23.4	Universal Jurisdiction. Limited, but potential “passive personality” exception.
Spanish CP	Art. 172 ter	Stalking (Acoso). Prosecutable in Spain if effect is felt there (“Ubiquity”).
Spanish CP	Art. 173	Crimes against Moral Integrity (Psychological Torture).

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