with lawyers take place in the office of the detention supervisor, who in such cases leaves the room. The detention supervisor's office has no bars on the window. As in the detention unit of the Split-Dalmatia County Police Administration, police officers are present during medical examinations. Rooms are generally in order, have artificial lighting, but natural light is very weak. Each room has two mattresses (one on a wooden base and, when required, one on the floor). Heating, cooling and ventilation are provided by an airconditioner. 2.2. Making proposals and observations concerning the existing laws and other regulations or their drafts Making proposals and observations concerning the existing laws and regulations or their drafts in order to promote the protection of persons deprived of their liberty from torture and other cruel, inhuman or degrading treatment or punishment is undoubtedly one of the key NPM activities. By encouraging amendments to the existing and adoption of new regulations, we are trying to promote systematic solutions of observed problems and thus prevent future potential violations of the rights of persons deprived of their liberty. However, with regard to this segment of our activities, we find it necessary to point out that sometimes, because of the volume or significance of proposed amendments, the time-limits for delivery of the opinion on particular draft regulations are too short. This prevents a systematic, analytical approach to some subject matters, which certainly has negative effects considering that our initiatives are directed at preventing one of the worst forms of human rights' violations. Act on Amendments to the Execution of Prison Sentences Act As the EPSA regulates the execution of prison sentences and, inter alia, prescribes the rights of prisoners and instruments for their protection, any amendment to that Act is considered to be exceptionally important. Within the procedure of adopting the Act on Amendments to the EPSA, we have supported the introduction of a new instrument for the protection of prisoners' rights – filing a complaint with the executing judge. However, considering the number of complaints from prisoners related to the duration of procedure by the executing judges, we proposed that a statutory time-limit of 30 days should be prescribed, in which the executing judge must respond to a complaint. In addition, we have disagreed with the proposed deletion of the provision prescribing the spatial standards for accommodation (4m2 and 10m3), as it clearly arises from the European Court of Human Rights' case law that, when examining accommodation conditions and potential violations of Article 3 of the European Convention for the Protection of Human Rights and Fundamental Freedoms, the Court considers 4 m2 as the minimum standard (e.g. Kalashnikov v. Russia (2003) and Cenbauer v. Croatia (2006)). Moreover, according to the CPT standards, 4 m² is the minimum requirement for living space per prisoner in multi-occupancy cells. Both of our proposals were accepted. Act on Amendments to the Criminal Procedure Act

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