departments do not produce accurate data on persons requesting or meeting a lawyer, provision of
medical services, etc. The production of documentation is not harmonious or unified and fails to
provide complete information about the detainee. In 17 of the 30 police facilities visited by the Special
Preventive Group, shortcomings were detected in the registers. In particular, in some cases, the
date/time of arrest is unavailable, the date/time when the detainee left the police division is unclear,
the time of taking the person to the temporary detention isolator precedes the time of the arrest, or the
time of bringing the person to the division precedes the time of the arrest, the date/time of the
detainee's transfer to prison/isolator is not specified.
It is important for the Ministry of Internal Affairs, at least in a pilot mode, to begin producing
systematized registers of detainees in police facilities, which would create additional safeguards against
torture and ill-treatment.
In terms of documentation, it is still problematic to properly fill in the detention documents. First of
all, the problem is that, unlike the document on the detention of a defendant on charges, the document
on administrative detention does not include a graph, where police officers would describe the injuries
on the body of the detainee. Therefore, some police officers try to describe injuries in some free space
of the paper. In 30.7% of the cases examined in 2019, the detention documents did not indicate the
injuries described in the examination report of the temporary detention isolator.249 Of these, in 125
(38.1%) of the 328 administrative cases examined, information of detention documents did not match
with information of documents produced by the isolator.
Documentation of disobedience/resistance and use of force is also faulty. Disobedience/resistance was
reported in 285 (63.8%) out of 447 cases in 2019.250 The use of force was indicated in 64 (14%) arrest
documents in 2019. The use of force was described in 12 of them. In one of these 12 cases, the use of
force was fully described and in 11 cases –partially described. Documentation on the legal measures
taken against the detainee by the police, especially in case of the use of force or special equipment,
would encourage higher sense of responsibility among police officers and help implementation of
control over the fulfillment of statutory obligations by them.
Overall, it should be taken into account that body cameras are in fact not used and the spaces in police
facilities, where detainees or persons with other status may be present, are not covered by a video
surveillance system. Consequently, if the detention document does not indicate an injury, resistance,
disobedience or use of force, a strong presumption arises that the detainee was subjected to physical
violence under police control. When a detainee is brought to a police facility in good health and leaves
249
About one-third of the cases reported in 2018, similar to 2017, does not indicate the injury described in the
external examination report (2018 - 27.6%, 2017 - 30.1%, 2016 - 31.3).
250 Compared to 2018, the percentage of resistance/disobedience increased.
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