Humane and dignified conditions in detention Table 8: Examples of detention conditions scrutinised by the ECtHR Example Case reference Article Even when accompanied by a parent, the detention of children in a closed centre can expose them to feelings of anxiety and inferiority, risking their development. ECtHR, Kanagaratnam and Others v. Belgium, No. 15297/09 (2011) Article 3 Article 5 (1) Families shall not be separated, and the authorities are required to do everything in their power to limit the detention of families with children. ECtHR, Popov v. France, Nos. 39472/07 and 39474/07 (2012) Article 8 Detention facilities that present a danger to children, such as those that contain iron-framed beds and automatic doors to rooms, as well as stress, insecurity and a hostile atmosphere, are ill suited for children. ECtHR, Popov v. France, Nos. 39472/07 and 39474/07 (2012) Article 3 Even in cases where the material conditions of detention are appropriate, the conditions inherent to detention establishments cause anxiety for young children. ECtHR, A.B. and Others v. France, No. 11593/12 (2016) Article 3 In the case of unaccompanied children, authorities must ensure ECtHR, Mubilanzila Mayeka that the child receives proper counselling and educational and Kaniki Mitunga v. Belgium, Article 3 assistance from a qualified person specially assigned to them. No. 13178/03 (2006) ECtHR, Mubilanzila Mayeka Unaccompanied children cannot be held in adult detention and Kaniki Mitunga v. Belgium, centres or in a youth hostel, which are unsuited to their No. 13178/03 (2006); Article 5 (1) extremely vulnerable situation (especially very young children). ECtHR, Housein v. Greece, No. 71825/11 (2013) When the detention conditions, particularly accommodation, hygiene and infrastructure, are so poor that they undermine human dignity, especially given the vulnerability of unaccompanied children, the detention is unlawful, even if it lasts only as long as two days. ECtHR, Rahimi v. Greece, No. 8687/08, (2011) Article 3 Source: FRA, 2017 Article 37 of the CRC requires States Parties to ensure that children in detention are treated with humanity and respect for their inherent dignity and in an age-appropriate manner.287 When detained, children should have the opportunity for regular contact with and visits from friends, relatives, religious, social and legal counsel, and their guardian.288 Children also continue to have the right 287 UN, Convention on the Rights of the Child, 20 November 1989, Article 37 (c). 288 Convention on the Rights of the Child, Article 37 (c); UN, International Convention on the Protection of the Rights of All Migrant Workers and Members of their Families, 18 December 1990, Article 17 (5). to education and recreation, and to medical treatment and psychological counselling where necessary.289 Table  9 summarises some of the main standards stemming from EU law, the ECHR and other international human rights law instruments in relation to various detention conditions applicable to children. 289 UN, Committee on the Rights of the Child, General Comment No. 6 (2005): Treatment of Unaccompanied and Separated Children Outside their Country of Origin, 1 September 2005, CRC/GC/2005/6, para. 63; UN, Rules for the protection of juveniles deprived of their liberty, A/RES/45/113, 14 December 1990 (Havana Rules), para. 38, which apply to any deprivation of liberty, on the right to education in detention. 71