The bill provides up to a 10-year sentence for physical or mental torture by the police. Article 38 of the constitution of the Islamic Republic forbids "all forms of torture for the purpose of extracting confession or acquiring information" and the "compulsion of individuals to testify, confess, or take an oath." It also states that "any testimony, confession, or oath obtained under duress is devoid of value and credence." The Islamic Republic itself vehemently denies the existence of torture by the government. Nonetheless, human rights groups and observers, such as Amnesty International, the United Nations, and Human Rights Watch, have complained that torture is frequently used on political prisoners in Iran. A substantial number of Iranians have been tortured and imprisoned by the religious police. Arya Aramnejad, a singer, was jailed for his song "Ali Barkhiz" where he denounces the Islamic regime's crimes during the 2009 Ashura protests. During his time in prison, he was reportedly tortured (sexually humiliated – photographed naked, laughed at, obliged to walk barefooted on aids' patients blood). Farzad Kamangar was repeatedly tortured in prison. Amnesty International reports that Kamangar was repeatedly beaten, flogged, and electrocuted, and that he now suffers from spasms in his arms and legs as a result of the torture. After she died in the custody of Iranian officials, Zahra "Ziba" Kazemi-Ahmadabadi, an Iranian-Canadian freelance photographer, was found to show obvious signs of torture, including a skull fracture, broken nose, signs of rape and severe abdominal bruising. Ehsan Fatahian, an Iranian Kurdish activist, was tortured for confession before being executed. Zeynab Jalalian, also a Kurdish activist, is currently ill due to prison conditions and torture. She has been sentenced to death. Other notable victims include Behrouz Javid Tehrani, Habibollah Latifi, Houshang Asadi, Saeed Malekpour, Shirkoh (Bahman) Moarefi, Hossein Khezri, and Akbar Mohammadi. In a study of torture in Iran published in 1999, Iranian-born political historian Ervand Abrahamian included Iran along with "Stalinist Russia, Maoist China, and early modern Europe" of the Inquisition and witch hunts, as societies that "can be considered to be in a league of their own" in the systematic use of torture. Torture techniques used in the Islamic Republic include:  whipping, sometimes of the back but most often of the feet with the body tied on an iron bed; the qapani; deprivation of sleep; suspension from ceiling and high walls; twisting of forearms until they broke; crushing of hands and fingers between metal presses; insertion of sharp instruments under the fingernails; cigarette burns; submersion under water; standing in one place for hours on end; mock executions; and physical threats against family members.