Cells Rule 10 of the UN SMR stipulates that: All accommodation provided for the use of prisoners and in particular all sleeping accommodation shall meet all requirements of health, due regard being paid to climatic conditions and particularly to cubic content of air, minimum floor space, lighting, heating and ventilation. The European Prison Rules (2006 revisions) use similar language, adding the importance of privacy (Article 18.1). Article 18.3 of the EPR stipulates that specific minimum requirements shall be set in national law. Cell size and fixtures are of particular importance where prisoners spend most of their day inside the cell in solitary confinement. While international instruments do not specify a minimum size for cells intended for solitary confinement, one can infer from judgements and reports what constitutes an acceptable standard. The European Committee for the Prevention of Torture (CPT) found that solitary confinement cells measuring 8 sq. m. (CPT re Germany, 1993) and 9 sq. m. (CPT re the Netherlands, 1993) to be of a ‘reasonable size’ for single occupancy, and cells measuring 11 sq. m. to be of a ‘good size’ (CPT re Netherlands, 1998). The European Court of Human Rights judged a cell measuring 6.84 sq. m. to be ‘sufficiently large’ for single occupancy (Ramirez v. France, Judgement of 27/1/2005). Clearly, any cell should be large enough to allow sufficient area for sleeping, eating and studying, whilst keeping the lavatory area separate. Windows and light The use of dark cells as punishment is prohibited under international human rights law (SMR 31; EPR 62.3). International standards also require that in all places where prisoners live or work: (a) The windows shall be large enough to enable the prisoners to read or work by natural light, and shall be so constructed that they can allow the entrance of fresh air whether or not there is artificial ventilation (SMR Rule 11a). Windows are particularly important where prisoners spend most of their day alone in the cell. The existence of windows, or lack thereof, as well as access to natural light for prisoners held in solitary confinement, have been important factors in the assessment of prison conditions by human rights bodies and the courts, and can tip the balance between acceptable conditions and inhuman treatment. In addition to natural light, international instruments also require that: Artificial light shall be provided sufficient for the prisoners to read or work without injury to eyesight (SMR Rule 11b) Cell fittings should enable prisoners to control artificial light inside their cells. In no case should cell lights be left on continuously. Sourcebook on solitary confinement: Design, physical conditions and regime in solitary confinement units 41