correct and human rights-based reforms. Accordingly, the Special Preventive Group conducted monitoring in Penitentiary Establishments Nos. 2, 8, 14 and 15 in July and August 2019. On July 24, 2019, a meeting was held with the Director General of the Special Penitentiary Service of the Ministry of Justice on the initiative of the Deputy Public Defender, where the latter briefed the Director General on the ongoing efforts aimed at examining the scale of informal governance in the establishments. At the end of 2019, the National Preventive Mechanism started to work on an annual report. On October 11, 2019, a letter was sent to the Special Penitentiary Service of the Ministry of Justice, requesting information on the situation of implementation of recommendations offered in the 2018 Report of the National Preventive Mechanism, but not reply has been received. Most of the letters sent in September, October, and November 2019,12 which requested the data required for the annual report have not been replied either. Despite numerous attempts of the National Preventive Mechanism, both through letters and telephone communication, the Ministry of Justice did not respond, which significantly hampered the process of processing various data and evaluating the implementation of recommendations. It should be noted that the delay in replying to the letters of the Public Defender represented the nonfulfillment of the legal demand and should have resulted in a fine.13 However, due to the fact that the Public Defender acted in the spirit of the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, which is based on a constructive dialogue, she refrained from applying the punitive mechanism in the reporting period. In early November 2019, the Special Preventive Group completed the process of drawing up a report on the monitoring carried out in Penitentiary Establishments Nos. 8, 14 and 15. On November 15, 2019, the report was sent to the Director General of the Special Penitentiary Service, who was asked to submit, within two weeks, his opinion on the issues and recommendations presented in the report. The reply received from the Director General of the Special Penitentiary Service on December 13, 2019 did not provide information on any strategy/plan to address the issues of criminal subculture and informal governance in the penitentiary facilities. The reply received from the Ministry refers to the cases of violence among prisoners. According to the Ministry, they launched investigations in 334 cases, but could not identify torture, other cruel, inhuman or degrading treatment among prisoners. 12 The National Preventive Mechanism sent letter No. 03-3/11037 on October 11, 2019, requesting information from the Special Penitentiary Service of the Ministry of Justice on the state of implementation of the recommendations offered in the 2018 Report of the National Preventive Mechanism. Repeated letter No. 033/13394 on the same issue was sent on 12 December 2019. Nevertheless, no reply has been received to any of the said letters. 13 Administrative Offences Code of Georgia, Article 1734. 13