-31 as a tool to extort a confession from a detainee awaiting trial is a clear form of torture and such a confession should be inadmissible in court.48 On the other hand, the jurisprudence of the European Court of Human Rights (ECtHR) does not consider a prisoner’s segregation as amounting to inhuman treatment in itself.49 In fact, in order to assess whether a violation of Article 3 takes place with regard to solitary confinement, the ECtHR considers the particular conditions of the case, the stringency of the measure, its duration, the objective pursued, and its effects on the person concerned. Moreover, the duration of such confinement is analysed by the ECtHR in conjunction with its justification, the need for the measures taken and their proportionality with regard to other possible restrictions, the guarantees offered to the applicant and the measures taken by the authorities to ensure that the applicant’s physical and psychological condition allowed him to remain in isolation.50 However, according to the ECtHR, complete sensory isolation coupled with total social isolation is regarded as a form of inhuman treatment, as it can destroy the personality of the detainee and cannot be justified by the requirements of security or any other reason.51 In its 21st General Report, the CPT states that the use of solitary confinement has to be justified in light of the extra restrictions imposed on the already highly limited rights of people deprived of their liberty. In order to assess the justification for the imposition of solitary confinement, the CPT uses a framework elaborated by the ECtHR, which analyses five elements: proportionality (of the measure as compared to the harm that the detainee has or is likely to cause, or to the potential harm that could be done to the prisoner by other detainees), lawfulness (it has to be regulated by domestic law, which should state the procedure for the imposition, the authorities who can impose the measure, mechanisms of review and of appeal, rights of the detainee, and a clear differentiation between each type of solitary confinement), accountability (full records should be maintained of all decisions to isolate detainees and of all reviews of the decision), necessity 48. United Nations General Assembly, Interim report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, A/71/298, 5 August 2016, §46. 49. European Court of Human Rights, Case of Öcalan v. Turkey (No. 2), Applications nos. 24069/03, 197/04, 6201/06 and 10464/07, 18 March 2014, §104. 50. European Court of Human Rights, Case of X v. Turkey, Application no. 24626/09, October 2012, §40. 51. European Court of Human Rights, Case of Öcalan v. Turkey (No. 2), §107. Monitoring Solitary Confinement in Prison