including people on managerial positions carried out violence against them when they were placing or had already placed them in the de-escalation room. Apart from the physical violence the prisoner from the N6 establishment mentioned the threatening of rape also took place, while the other one claimed that in the de-escalation room he was not provided with drinking water for a long time. As for the three reports received from the penitentiary establishment N8, one of them reported the alleged violence against 3 inmates. The prisoners from the N8 establishment reported that together with the violence by the personnel and the management, a threat of rape also took place. In one case attaching to a pipe for 10-15 minutes using handcuffs, as well as not providing medical care, food and drinking water in the descalating room. When assessing the extent of violence against prisoners by penitentiary staff, in addition to the information received during preventive visits, the available data on criminal cases produced by the State Inspector's Office are to be taken into account. According to the State Inspector's Office,44 an investigation has been launched on 30 criminal cases involving alleged physical and/or psychological violence against prisoners by Penitentiary Service staff in 2020, including 5 criminal cases under Article 1443 and 25 criminal cases - under Article 333. In 27 of the mentioned 30 criminal cases, the prisoner indicated the fact of physical violence, and in 3 cases there was inhuman and degrading treatment. Out of the mentioned 30 cases, the alleged violence took place in the following penitentiary institutions: 1 case in N2 establishment, 4 cases in N3 establishment, 9 cases in N6 establishment, 1 case in N7 establishment, 13 cases in N8 establishment, 2 cases in N18 establishment. It should be noted that the Prosecutor General's Office of Georgia has not initiated criminal proceedings against any employee of the Special Penitentiary Service on any of the criminal cases. 2.3.1.2. Violence among the inmates In conflicts between individuals in penitentiary establishments, a positive obligation of a state to protection arises.45 The administration of the facility is obliged to know if there is a threat of violence and to take reasonable measures to prevent it.46 In 2020, overcrowding and informal ruling in penitentiary establishments are still problematic, often leading to physical and psychological violence among prisoners. The reason for the dispute is mainly everyday life issues, unauthorized use of the phone card of another prisoner, request/seizure of cigarettes and extortion of money. Prisoners talk to a special preventive group about conflicts and physical confrontations taking place in the establishments and that this is a normal story of "prison life" as well as for an outside life. However, due to the influence of the criminal subculture and the fear of repression, most prisoners avoid talking about the details of conflicts with a special preventive group. During a visit to the N8 penitentiary establishment, a special preventive group received three reports of physical and psychological abuse of Letter SIS 22000020027 of December 8, 2020 from the State Inspector of Georgia. Report of the UN Special Rapporteur on Torture, Other Inhuman and Degrading Treatment E / CN.4 / 2003/68, para.26. Available at: < https://undocs.org/E/CN.4/2003/68 >, [last visited: 01.12.2020]. 46 The decision of the European Court of Human Rights on the case of I.E. against Moldova (I.E. v. The Republic of Moldova (app no. 45422/13)), para. 46. 44 45 33