A/69/44 (c) Adoption of the basic policy guidelines for the enforcement of prison sentences and detention of juveniles for 2007–2013, on 2 March 2010; (d) Adoption by the Cabinet of Ministers of the regulation setting out the procedure for providing community service as an alternative to imprisonment, including in the case of minors, on 9 February and 3 August 2010; (e) Publication by the Office of Citizenship and Migration Affairs of a commentary to the Asylum Law, with a view to improving the quality of the asylum procedure, January 2010. C. Principal subjects of concern and recommendations Definition of torture (7) While taking note of the amendments to the Law on the Procedures for the Coming into Force and Application of the Criminal Law, supplementing the law with article 24.1 which defines torture, and recalling its previous concluding observations (CAT/C/LVA/CO/2, para. 5), the Committee is concerned that the definition of torture does not reflect all of the elements contained in article 1 of the Convention, which may create loopholes for impunity, as outlined in general comment No. 2 (2007) on implementation of article 2 by States parties (art. 1). The State party should amend its legislation to include a definition of torture in conformity with the Convention, which covers all the elements contained in article 1, including the inflicting of torture on a person for such purposes as obtaining from him or a third person information or a confession, punishing him for an act he or a third person has committed or is suspected of having committed, or intimidating or coercing him or a third person, or for any reason based on discrimination of any kind, when such pain or suffering is inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting in an official capacity. Torture as a specific criminal offence and the statute of limitations for acts of torture (8) The Committee is concerned that, since torture is not a separate offence under Criminal Law, the penalties for acts of torture have been incorporated into different articles of the Criminal Law, that are not appropriate punishment for such criminal offences, taking into account their gravity. It is also concerned that acts of torture and attempts to commit torture, as well as acts by persons that constitute complicity or participation in torture, are subject to a statute of limitations of 10 years in most cases, which may result in impunity for perpetrators of such acts (arts. 2 and 4). The State party should amend its legislation to include torture as a specific offence in the Criminal Law, with appropriate penalties for acts of torture that take into account their grave nature, as set out in article 4 (2) of the Convention. In addition, the State party should ensure that the prohibition against torture is absolute and that there is no statute of limitations for acts of torture, so that acts of torture and attempts to commit torture and acts by persons which constitute complicity or participation in torture can be investigated, prosecuted and punished without time limitations. Fundamental legal safeguards (9) The Committee is concerned that persons deprived of their liberty do not enjoy in practice all the fundamental legal safeguards against torture and ill-treatment that should be afforded from the very outset of deprivation of liberty, such as access to a lawyer and an independent doctor and the right to inform a relative or person of their choice from the very outset of their detention. It is also concerned at reports of a shortage of lawyers and that lawyers providing “State-ensured legal aid” are reluctant to do so for lack of appropriate remuneration (arts. 2, 12, 13 and 16). 46 GE.14-12596