problems regarding conditions of detention or treatment of detainees, the NPM would take it up. The NPM in Cyprus was of the view that the question of transfer and the impact on the prevention of ill-treatment was a relevant topic for their consideration, and without doubt a part of their mandate. In light of it being a relatively new area, it has not been fully addressed yet, and recommendations to authorities have not been made to date, but this is something that they intend to work on in the future. 3.2. the potential in using npm reports in cross-border transfer cases As outlined above, the provision of reliable information on conditions of detention in the country to which the person is supposed to be transferred to might constitute a challenge, as ECtHR judgments and CPT reports might be quite old and lacking specific enough information. In the analysis of the replies to the Commission’s Green Paper on Detention, several EU Member States “underlined the practical issue of finding up-to-date information concerning the prison conditions and criminal justice systems of other Member States.” 310 Several judges and representatives of Ministries of Justice interviewed in the framework of this project confirmed that it was difficult to obtain information regarding conditions of detention in other EU Member States, especially information that is reliable and up to date.311 Many of the judges and Ministry of Justice representatives commented that NPM reports could be particularly useful when taking decisions on whether an individual’s surrender might possibly violate Article 3 ECHR. The CJEU in its judgment on Aranyosi and Caldӑrӑru found that in order to make an informed decision, the executing States needs to receive, “information that is objective, reliable, specific and properly updated on detention conditions prevailing in the issuing Member State and that demonstrates that there are deficiencies, which may be systematic or generalised, or which may affect certain groups of people, or […] certain places of detention.”312 Furthermore, the CJEU stipulates that the information required in order to assess the situation should be provided by, “[...] inter alia, judgments of international courts, such as judgments of the ECtHR, judgments of courts of the issuing Member State, and also decisions, reports and other documents produced by bodies of the Council of Europe or under the aegis of the UN.”313 The authors of this report are of the view that with the reference to reports “under the aegis of the UN” the Court acknowledges the role of NPMs as institutions being established following OPCAT as a UN treaty. There exists a great culture of complementarity amongst the mechanisms outlined by the Court. The NPMs, however, have several distinct advantages over the other monitoring bodies referred to by the CJEU, which will be further considered. 310 See Analysis of the Replies to the Green Paper on the Application of EU Criminal Justice Legislation in the Field of Detention, p. 8. Countries and actors having this concern at the time were CZ, DK, LV, RO, NL, as well as the Council for the Administration of Criminal Justice and Protection of juveniles. 311 Interview with Judge Ingrid Haussman, 5 October 2016. Interview with Barbara Göth-Flemmich and Andrea Rohner, Austrian Ministry of Justice, 28 October 2016. 312 Ibidem, para. 89. 313 Ibidem. 86