Talk:Clean Hands/@comment-78.146.236.203-20121201013334

You can actually kill the torturer and still get this achievement. (End-Level stats will show a tick next to Didn't kill anyone). BUT! You have to choke him and kill him by dropping him from a great height. (I dropped him down from the top stairs/floor of the radio tower.

Going by this I think indirect kills like this count towards this achievement (i.e drowning, getting eaten by rats, falling from a great height. I might be wrong though, haven't checked fully.)