provided, and prisoners are informed orally against signature. The refusals themselves do not also indicate the right of appeal to the Minister of Justice. The findings appeared to be reason for the NPM to accept that the right of appeal and use of legal protection are hindered and restricted. These acts are hardly challenged, and new applications are being written to the Minister of Justice. Provision of Art. 64 of the Law on Implementation of Penal Sanctions and Detention provides inmates with good behaviour who have served at least six months of the sentence in prison or prison dormitory of closed type and have a remainder of his/her sentence not greater than 5 years to be served, to be relocated to serve their sentence in prison dormitory of open type (open dormitory). On the background of such provisions where there is no distinction between offenders and recidivists, the provisions of art. 70 of the Criminal Code regulating the possibility of early release of prisoners really impress. They require half of the sentence to be served, and for recidivists the requirement is to have served two-thirds of the sentence, but the rest of it shall not be less than three years. According to the NPM, provided that there is no statutory limit on the minimum remainder of actually served sentences for offenders concerning conditional early release, such remaining term for recidivists is unfair and is a factor that leads to overcrowding in prisons. The LIPSD allows inmates who are serving a sentence in a prison dormitory of open type to be moved to a prison or a prison dormitory of closed type when they carry out gross or systematic violation of the established order, systematically deviate from a job or have adverse affect other. According to the NPM, the term “deviation from work” should be more precise. The work of the prisoner is his own right, not an obligation. Imposition of a disciplinary sanction for refusing to carry out the work is unacceptable. Decisions on transfer to a dormitory and back to prison shall be motivated by the results of the evaluation of the convicted under art. 64, para 3 of the LIPSD and are subject to appeal. Concerning the other two types of decisions of the commission on regime change and early release on parole the law does not prohibit their appeal, but does not specify the competent court and/or administrative body. In the old Law on Implementation of Penal Sanctions there was a possibility for an administrative appeal. Now the practice assumes that such acts are non-appealable. The finding of the NPM is negative that decisions for relocation, regime change and early release on parole of the commission under art. 73 of the LIPSD are not motivated in compliance with the requirements of art. 55, para 5 of the RALIPSD with the required risk assessments. The only exception to this is the work of the commission in prison in the city of Belene. The Commission's refusal is not provided in writing to the inmates. They are informed against signature, which hinders their right to appeal against such decisions. The lack of information often leads to acts of dissent by launching hunger strikes, self-harm, unreasonable aggression towards supervisory staff and render difficulties to the administration in the detention facilities. With no doubt, this right is related also to the revaluation of the caseload of social workers that are often responsible for 100 to 200 inmates. The NPM believes that giving publicity to the decisions of the commissions under art. 73 among prisoners through appropriate 9 Annual Report of the National Preventive Mechanism | OMBUDSMAN OF THE REPUBLIC OF BULGARIA