6. Opinion of the Public Defender on the Action Plan for Combating Torture 2021-2022 In this chapter, we present the views of the Office of the Public Defender of Georgia on the 2021-2022 Action Plan against Torture, Inhuman or Degrading Treatment or Punishment approved by the Interagency Coordination Council implementing the Measures against Torture, Inhuman, Degrading Treatment or Punishment. The Action Plan 2021-2022 on Combating Torture is of great importance in the process of improving existing legislation and practices on combating torture in the country and harmonizing it with international standards. When developing an action plan, of great importance is the inclusiveness of the process, the content of the plan and the strengthening of accountability mechanisms. This document is a set of actions of the state to address all the problems that exist in the direction of the prohibition of torture. Therefore, it is important that this document responds accurately to the real challenges and that the activities envisaged are aimed at effectively addressing the shortcomings. In the context of the inclusiveness of the process, it is important to ensure stakeholder engagement in the working format and constructive dialogue when developing the plan. For this purpose, sufficient time must be allocated. It is unfortunate that work on the plan was hasty and limited to only a few formal stages. The Office of the Public Defender had to formulate its opinion regarding the action plan in writing in a short period of time. In particular, on January 25, 2020, the Secretariat of the Interagency Coordination Council sent us a draft action plan, which already reflected a number of recommendations of the Public Defender, and asked us to submit our views by January 28, 2020. It is true that this term was extended to 10 days after the request of the Public Defender's Office, but it would be important for the Public Defender to be involved in the process from the very beginning. Despite the tight deadlines, the Public Defender still took the opportunity to submit additional opinion and provided up to 40 important, systemic recommendations to the secretariat. It is unfortunate that out of the recommendations submitted by the Public Defender, only 2 recommendations were taken into account in the final draft of the plan.510 It is unfortunate that the Public Defender's office did not receive an answer as to why most of the ombudsman's recommendations were not accepted by the agencies (except for a few arguments presented at the council meeting). In addition, in the process of working on the plan, no joint working groups were set up, where the Public Defender, together with representatives of various agencies, international and non-governmental organizations, would have the opportunity to discuss in detail both the recommendations and international standards for prevention of torture. Activities of the Plan should respond as much as possible to the challenges existing in the country. It is important that the action plan is based on reports, research, resolutions, recommendations and other documents from international organizations, the Public Defender and local organizations. The Public 1) The proportion of long-term inpatients and patients with mental disabilities who have been placed in psychiatric institutions for more than 6 months and who have been transferred to a shelter has increased by 10%; 2) Introduction of a sample confirming the receipt-delivery of a letter from the accused/convict by the social worker in the penitentiary system. 510 149