Britain slow to learn from the Abu Ghraib scandal

In America, the Abu Ghraib prison abuse scandal was already under investigation before the photographs of the prisoners' humiliation became public. In Britain, there may never have been an investigation of Iraqi prisoner abuse that led to the court martial of four British soldiers in Germany this week had it not been for the action of an alert photo shop assistant.

In America, the Abu Ghraib prison abuse scandal was already under investigation before the photographs of the prisoners' humiliation became public. In Britain, there may never have been an investigation of Iraqi prisoner abuse that led to the court martial of four British soldiers in Germany this week had it not been for the action of an alert photo shop assistant.

But the two scandals have some startling similarities, raising questions about the level of complicity along the military chain of command and within the Anglo-American coalition.

In the photographs from Abu Ghraib and in those from the court martial, naked Iraqi prisoners are being subjected to sexual abuse and humiliation.

Among the British court martial pictures is one showing two kneeling Iraqi men giving the thumbs-up as they are apparently engaged in a sex act. The image is reminiscent of the US Army reservist, Charles Graner, giving a smiling thumbs-up as he had himself photographed behind a pile of naked Iraqi prisoners at Abu Ghraib. Graner was sentenced last Saturday to 10 years in jail.

Both Graner and the British soldiers say that they were only following orders.

On 28 April 2004, the American CBS network published the first photographs on Sixty Minutes II, including the iconic picture of a hooded Iraqi standing on a box, with wires attached to his hands.

But trouble had been brewing in the American and British-run jails ever since the fall of Iraq. Despite entering Iraq as "liberators" in March 2003, US and British troops were continuing to come under attack and by the summer of 2003 had imprisoned 850 people in Abu Ghraib, including dozens suspected of links to al-Qa'ida.

Leaked memos from the Bush administration, which had not hidden its disdain for the Geneva Conventions, have confirmed that the US "war on terror" had given rise to a permissive climate of abuse by American interrogators.

But it was a soldier, Specialist Joseph Darby of the 372nd Military Police Company, who on 13 January 2004 alerted army investigators to the many incidents of prisoner abuse in the interrogation facilities at Abu Ghraib, by handing over a CD containing the pictures. The following day, a criminal investigation was ordered by the US commander in Iraq, Lt Gen Ricardo Sanchez, and by the end of that month a broader administrative inquiry into the prison procedures was launched by Maj Gen Antonio Taguba.

His report was leaked to the American investigative journalist Seymour Hersh, who detailed the scale of the abuse in The New Yorker two days after CBS published the pictures.

But British authorities had also been alerted to abuse by British troops in the southern sector around Basra.

The International Committee of the Red Cross warned British and US coalition authorities last February the prisoner abuse also involved British soldiers.

Last May, with the Abu Ghraib scandal in full swing and the British military's "Ali Baba" anti-looting operation under way, the MoD assured the public it had acted on recommendations from the "interim" Red Cross report. But the announcement was only made after the Red Cross alarm had become public, thanks to a leak in The Wall Street Journal.