So-called pain holds – such as nerve pressure techniques applied to the temple – are used by the police to break resistance through targeted pain, often during sit-ins at demonstrations. Legally, this constitutes direct coercion, which, as a factual act, can be reviewed by the administrative court by way of a declaratory action (§ 43 VwGO).

Their very suitability is questionable: Unlike simply carrying someone away, pain holds do not exert physical force themselves, but rather rely solely on pain or the threat of it – they are intended to force the person to "voluntarily" release the hold or move. If carrying the person away is a less intrusive and equally effective method, the additional pain is generally unnecessary – especially if the person is already on the ground. Particularly in such situations, a pain hold can constitute inhuman or degrading treatment and thus a violation of the prohibition of torture under Article 3 of the European Convention on Human Rights, especially if the person's behavior did not necessitate its use. Furthermore, human dignity (Article 1 of the German Basic Law) and physical integrity (Article 2, Paragraph 2 of the German Basic Law) are also affected.

Several court rulings have set limits on these measures – both formally and substantively. For example, the Higher Administrative Court of Lower Saxony (judgment of October 28, 2016 – 11 LB 209/15) , in cases of significant infringements on physical integrity, a qualified warning specifically related to the particular coercive measure to be used, so that the person affected is clear about the impending infringement. In terms of content, the Administrative Court of Göttingen (judgment of September 3, 2025 – 1 A 191/23) declared the temple hold applied to a demonstrator already lying on the ground to be disproportionate and therefore unlawful – in line with other chamber decisions and the jurisprudence of other courts (e.g., Administrative Court of Berlin, judgment of March 20, 2025 – 1 K 281/23).