2022, Benhalima was notified that he had already been sentenced to death in absentia by a military court while he was still in Spain. In June 2022, he declared in court that he had been subjected to torture. Spain is a member of the European Union and the Council of Europe, both bodies that have passed resolutions to combat transnational repression. Bahrain Ahmed Jaffer Muhammad, a Bahraini critic of the government who fled to Serbia after government authorities tortured and ill-treated him, was extradited in January 2022 after Bahraini authorities issued a Red Notice through Interpol.3 Bahraini courts had sentenced him to life in prison following unfair, in absentia trials. In permitting the extradition, Serbia violated the principle of nonrefoulement, as Muhammed had previously been tortured and ill-treated while detained in Bahrain and risked these abuses again. Further, the Serbian government ignored an order by the European Court of Human Rights prohibiting his extradition pending more information on the risks of torture or mistreatment upon return. While detained, Muhammad wrote to the Higher Court in Belgrade on four occasions stating his intention to seek asylum, but his extradition was approved despite this request. Muhammad is now imprisoned in Bahrain, serving a life sentence. Cambodia The Cambodian government has repeatedly reached across its borders to repress critics of the government and exiled opposition party members, including those recognized as refugees. In many cases, the government of Thailand has helped facilitate Cambodia’s transnational repression. In 2017, political dissident Sam Sokha gained notoriety after throwing a sandal at a photo of Cambodian Prime Minister Hun Sen. After Cambodian authorities issued a warrant for Sokha’s arrest for “insult of a public official” and “incitement to discriminate,” Sokha fled to Thailand, where she applied for asylum and was registered as a refugee by UNHCR. Despite her protected status, Thai authorities arrested her and authorized her extradition to Cambodia in February 2018. 3 See discussion of Interpol Red Notices, below. 9 HUMAN RIGHTS WATCH | FEBRUARY 2024