The analysis in this chapter suggests that the term 'treatment' is the unassuming hub of Article 3's past and future scope of meaning. It interprets the term 'treatment' in a way that progresses the existing authoritative interpretation. The authoritative interpretation, however, is only implicit in the jurisprudence. The chapter categorizes the approaches to treatment's meaning in the Court's judgments. It suggests three conceptual groupings, giving some examples of each in order to convey the breadth of the idea as manifested in the case-law. Three rough categories are listed: physical intrusion, conditions, and manners. The Court has recognized inhuman and/or degrading environments outside of contexts of detention. The Convention drafters, in approving the language of inhuman and degrading 'treatment', likely had in mind ill-treatment of an individual by an identifiable individual or group. The essence of treatment's interpretation is not that it takes a particular form, but that it must express some kind of social relationship that impacts upon an applicant.