reviewing the plans so as to secure their commitment to the implementation of the plans and to their social rehabilitation.81 In those circumstances where individual sentence planning is formalistic and activities carried out in penitentiary establishments in terms of rehabilitation and resocialisation are not tailored to individual needs of convicted persons, it is imperative to ensure that rehabilitation programmes implemented in 2018 in low-risk prison facilities are implemented in the semi-open prison facilities. It is also important to ensure that rehabilitation programmes implemented in 2018 in the semi-open prison facilities are implemented in the closed type prison facilities also, taking into account the infrastructure and security considerations and ensure that rehabilitation programmes implemented in 2018 in the closed type prison facilities are implemented in special risk prison facilities too, taking into account the infrastructure and security considerations. Furthermore, it is imperative that, in 2019, rehabilitation programmes in each penitentiary establishment should cover more prisoners. In terms of rehabilitation and resocialisation, the situation in special risk penitentiary establishments is particularly difficult.82 Being locked up in cells for 23 hours without interesting and engaging activities in closed-type and special risk facilities strengthens the feeling of protest, unfairness and hopelessness, which creates additional problems in terms of order and security. It is noteworthy that the same problem is pointed out by the CPT in its report to the Georgian Government on the visit carried out in Georgia in 2018. According to the CPT, as had been the case during previous visits, progress had been much less impressive in drawing up programmes for purposeful, out-of-cell activities for prisoners. The delegation again observed that prisoners in closedtype establishments visited (establishments nos. 3, 6, 7, 8 and 9) were locked up in their cells for most of the day, in a state of enforced idleness. For some of them (those in the so-called “high-risk” category), the regime could amount to de facto solitary confinement for years on end. The situation was not much better in semi-open establishment no. 15 – although not locked up during the day and free to move around the prison premises, inmates were basically left with nothing to do.83 The Public Defender’s recommendations made in 2017 concerning increasing the daily duration of the time spent in the open air (which is one hour) and arranging appropriate conditions for physical exercise in closed-type and special risk penitentiary establishments has not been fulfilled. At the same 81 Report to the Georgian Government on the visit to Georgia, carried out by the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) from 10 to 21 September 2018, (CPT/Inf (2019) 16), para. 74, available in English at: https://rm.coe.int/1680945eca, (accessed 15.05.19). 82 In 2018, there were only 5 rehabilitation programmes implemented in penitentiary establishment no. 3; only one rehabilitation activity was implemented in penitentiary establishment no. 6 and no rehabilitation activities were implemented in penitentiary establishment no. 7. There is a psychologist working individually with some convicted persons in these penitentiary establishments, which is not conducted systematically. 83 Available at: https://rm.coe.int/1680945eca, p. 5, (accessed 26.05.2019). 36