In order to effectively identify and document the facts of ill-treatment, the Ministry should develop and implement the Rules for reporting to independent investigative and monitoring bodies the actions referred to in Articles 15 and 16 of the Convention on the Rights of Persons with Disabilities (torture or cruel, inhuman, degrading treatment or punishment, exploitation, violence and abuse). For years the Public Defender has been recommending that in order to prevent cases of violence in psychiatric institutions, the Ministry should develop and implement a strategy for conflict prevention between patients and response on it, which will also include documenting the cases of violence in a special journal and assistance to victims of violence; also, in order to prevent critical situations in psychiatric institutions, it is important to develop and implement a mandatory internal crisis prevention and management guideline document for psychiatric institutions so that institutions minimize the risks of escalation of the situation and therefore no longer need to take extreme measures. In addition, in order to reduce and eliminate the use of restraints in psychiatric institutions, it is important to update the instructions on the rules and procedures for the use of methods of physical restraint in consultation with the Public Defender's Office and organizations of persons with disabilities. It is unfortunate that these issues were not included in the action plan. One of the activities of the plan was to provide quality medical services in psychiatric institutions in accordance with the international human rights standard. According to the Public Defender, it would be important to include in the plan as the activity a recommendation to provide planned medical care to patients admitted to a psychiatric hospital in the presence of somatic health problems. The above recommendations are also reflected in the 2020 Parliament Resolution. It is unfortunate that this issue was not included in the action plan. 6.3. System of the Ministry of Internal Affairs It is unfortunate that instead of incorporating the recommendations issued by the Public Defender, the plan identified the need to study international practice in relation to safeguards for the protection of detainees from ill-treatment. In view of the Public Defender, it would be important for the plan to directly reflect guarantees for the protection of detainees, such as: the obligation to register all detainees transferred to police stations, production of audio and video recordings, including the interrogation of detainees, etc. In addition, the issue of developing and introducing a mechanism for recording the request of a lawyer and the time of contacting a lawyer was completely removed from the plan activities. 152

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