5.2. Inherently inappropriate mechanical restraints Whilst international and regional human rights and policing standards recognise that certain mechanical restraint devices, when used appropriately, can be legitimate tools of restraint in effective law enforcement, other forms of mechanical restraint are inherently inappropriate or abusive in nature and should never be employed in law enforcement or detention. As previously noted, Rule 47 of the Mandela Rules states that “the use of chains, irons or other instruments of restraint which are inherently degrading or painful shall be prohibited.” 174 Similarly, under Article 68.1 of the European Prison Rules, which were adopted by the Committee of Ministers of the CoE, “The use of chains and irons shall be prohibited.” 175 However, despite these restrictions, the Omega Research Foundation has documented the development, promotion, transfer and/or use of restraints that are inherently inappropriate for law enforcement, within the CoE region, from 2012-2017. 5.2.1. Fixed restraints Some restraints, specifically intended for use on human beings, are designed to be fixed integrally to the wall or floor of a prison or detention facility. They have been developed in various forms, including isolated cuffs (for securing one ankle or wrist); wall attachments such as rings or hooks; and elaborate four-point floor and wall restraints (securing a detainee’s ankles and wrists). 5.2.1.1. Torture and ill-treatment utilising fixed restraints The CPT has previously stated that “[c]haining inmates to […] fixed objects is totally unacceptable in any circumstances and could be considered as inhuman and degrading treatment.”176 In addition to the ad hoc employment of standard handcuffs to attach prisoners to fixed objects such as chairs, beds, doors, etc which has been reported by the CPT for example in Bosnia & Herzogovina177, Greece178, Italy179, the Ukraine180; the CPT, the UN Special Rapporteur on Torture and Amnesty International have documented the use of fixed restraints in Bulgaria,181 Germany182, and the Russian Federation. 183 5.2.1.1.1. Illustrative cases Bulgaria In a report following its 2014 visit, a CTP delegation “heard allegations of ill-treatment of such a severity that it would amount to torture, such as …blows with truncheons inflicted to a person attached with handcuffs to hooks fixed to a door frame (and thus immobilised in a 174 UN, Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules), United General Assembly resolution 70/175, annex, adopted on 17 December 2015, Rule 48. 175 CoE, Recommendation of the Committee of Ministers to member States on the European Prison Rules, adopted by Committee of Ministers on 11th January 2006 at 952nd meeting of the Ministers’ Deputies, Article 68.1. 176 See for example: CPT, Report to the Government of “the former Yugoslav Republic of Macedonia” on the visit to "the former Yugoslav Republic of Macedonia" carried out by the CPT from 15 to 26 May 2006, 13 February 2008, paragraph 50. 177 CPT (5 July 2016) op.cit., paragraph 38. 178 CPT (26 September 2017) op.cit., paragraph 53 . 179 CPT (8 September 2017) op.cit., paragraph11. 180 CPT (19 June 2017) op.cit., paragraph 17. 181 CPT (29 January 2015) op.cit. 182 CPT, Report to the German Government on the visit to Germany carried out by the CPT from 25 November to 2 December 2013, 24 July 2014; CPT, Report to the German Government on the visit to Germany carried out by the CPT from 25 November 2015 to 7 December 2015, 1 June 2017. 183 CPT (17 December 2013) op.cit. 183 CPT (17 December 2013) op.cit., Paragraph 112. 37