CCPR/C/GC/35 instance or on appeal, does not in and of itself render any preceding detention “unlawful”.155 52. The financial compensation required by paragraph 5 relates specifically to the pecuniary and non-pecuniary harm resulting from the unlawful arrest or detention.156 When the unlawfulness of the arrest arises from the violation of other human rights, such as freedom of expression, the State party may have further obligations to provide compensation or other reparation in relation to those other violations, as required by article 2, paragraph 3, of the Covenant.157 VII. Relationship of article 9 with other articles of the Covenant 53. The procedural and substantive guarantees of article 9 both overlap and interact with other guarantees of the Covenant. Some forms of conduct amount independently to a violation of article 9 and another article, such as delays in bringing a detained criminal defendant to trial, which may violate both paragraph 3 of article 9 and paragraph 3 (c) of article 14. At times the content of article 9, paragraph 1, is informed by the content of other articles; for example, detention may be arbitrary by virtue of the fact that it represents punishment for freedom of expression, in violation of article 19.158 54. Article 9 also reinforces the obligations of States parties under the Covenant and the Optional Protocol to protect individuals against reprisals for having cooperated or communicated with the Committee, such as physical intimidation or threats to personal liberty.159 55. The right to life guaranteed by article 6 of the Covenant, including the right to protection of life under article 6, paragraph 1, may overlap with the right to security of person guaranteed by article 9, paragraph 1. The right to personal security may be considered broader to the extent that it also addresses injuries that are not life-threatening. Extreme forms of arbitrary detention that are themselves life-threatening violate the rights to personal liberty and personal security as well as the right to protection of life, in particular enforced disappearances.160 56. Arbitrary detention creates risks of torture and ill-treatment, and several of the procedural guarantees in article 9 serve to reduce the likelihood of such risks. Prolonged incommunicado detention violates article 9 and would generally be regarded as a violation of article 7.161 The right to personal security protects interests in bodily and mental integrity that are also protected by article 7.162 57. Returning an individual to a country where there are substantial grounds for believing that the individual faces a real risk of a severe violation of liberty or security of 155 156 157 158 159 160 161 162 16 432/1990, W.B.E. v. Netherlands, para. 6.5; 963/2001, Uebergang v. Australia, para. 4.4. 1157/2003, Coleman v. Australia, para. 6.3. Ibid., para. 9; 1128/2002, Marques de Morais v. Angola, para. 8; general comment No. 31, para. 16. See also paragraph 17 above. General comment No. 33, para. 4; 241 and 242/1987, Birindwa ci Birhashwirwa and Tshisekedi wa Mulumba v. Zaire, para. 12.5; see concluding observations: Maldives (CCPR/C/MDV/CO/1, 2012), para. 26. 449/1991, Mojica v. Dominican Republic, para. 5.4; 1753/2008, Guezout et al. v. Algeria, paras. 8.4 and 8.7. 1782/2008, Aboufaied v. Libya, paras. 7.4 and 7.6; 440/1990, El-Megreisi v. Libyan Arab Jamahiriya, para. 5.4. General comment No. 20, para. 2.