recommendation to develop a strategy to tackle the criminal subculture and informal governance in penitentiary establishments has not been implemented. Despite the recommendation of the European Committee for the Prevention of Torture (CPT)35 and the Public Defender, victims of violence have not been protected (transferring to other establishments or avoiding contact with prisoners from a criminal subculture). As a result of the monitoring, it is clear that in 2020, the administration of the establishments not only did not protect the prisoners who were victims of violence, but did not protect the representatives of the Public Defender's Office from the verbal attacks, threats and aggression carried out by the so called "prison watchers" due to which the Public Defender made a number of public statements.36 The Public Defender welcomes the adoption of a new rule to increase the effectiveness of the procedure for detecting, documenting and reporting cases of violence to the investigative body,37 which defines the obligation of the doctor to send a notification about the alleged fact of ill-treatment directly to the State Inspector of Georgia. A change is also welcome, according to which the doctor, in case of suspicion of torture and ill-treatment, is obliged to describe the injury, take a photo and send it to the investigating authority regardless of whether s/he received informed consent of the prisoner. It is regrettable that during the reporting period, the doctors of the penitentiary establishments did not undergo training on documenting the injury and taking photos. The response sent to the Parliament by the Ministry of Justice states that a new training module had been developed in accordance with the new order, according to which it was planned to train medical staff. The response states that the training process was delayed due to COVID 19. We hope that the training process will start in the near future. The basic recommendations on improving living conditions have not been implemented either. Improving the conditions in penitentiary establishments and unloading cells is especially important in pandemic conditions, because the sanitary-hygienic conditions in overcrowded cells pose a great challenge in terms of the spread of infection in cells. In order to provide 4 sq.m. living space to each prisoner the Public Defender requested equal distribution of prisoners in the cells of N2, N8, N14, N15, N17 establishments and transfer to other institutions of the same type, taking into account the place of residence of the prisoners. The recommendation has not been fulfilled. It should be noted that the number of prisoners in N2, N8, N14, N15, N17 establishments has not changed significantly compared to the previous year. Consequently, the above-mentioned penitentiary establishments were not unloaded. Moreover, in 2020, N15, N2 and N8 penitentiary establishments still housed more prisoners than provided by the limit.38 Despite the recommendation of Report on the visit of the European Committee for the Prevention of Torture to Georgia (CPT/Inf (2019) 16), para. 47, September 10-21, 2018, available in English at: https://rm.coe.int/1680945eca [last visited: 21.01.21] 36 The special statement of the Public Defender of Georgia regarding the situation in the penitentiary establishments is available at the following address: https://cutt.ly/0j0Uo6Q [last visited: 21.01.21] 37Order №663 of the Minister of Justice of Georgia of November 30, 2020, on the approval of the rules for the registration of injuries of accused/convicts as a result of possible torture and other cruel, inhuman or degrading treatment in penitentiary institutions. 38 For detailed information, see the relevant subchapter - Conditions of Detention. 35 27