The Special Preventive Group considers that the location, quantity and quality of some bodily injuries described in the documents of the penitentiary facilities may indicate alleged violence.71 It is worth noting that all of the above cases included signs of alleged violence against prisoners, although no document was filled out to register the injuries in accordance with the order of the Minister. According to the information provided by the Ministry of Justice of Georgia, from January 1 to November 30, 2019, there were 316 cases of infliction of bodily injuries to a prisoner by another person.72 The Special Preventive Group beleives that the faulty practice of detecting and documenting the cases of alleged violence in penitentiary facilities, inter alia,73 is caused by inadequate qualifications of doctors; the lack of confidential environment for meeting a prisoner; the obligation to obtain informed consent from the prisoner for filling out the relevant document. Doctors' qualifications: The monitoring results show that if there are suspicious injuries, doctors do/can not make efforts to obtain information on alleged violence. In addition, it should be noted that one of the doctors on duty at Penitentiary Establishment No. 15 was not aware of the rules for documenting injuries under the Istanbul Protocol at all.74 As for the quality of documentation of alleged violence, the documents examined by the Special Preventive Group in Establishments Nos. 2 and 8 show that the injury description charts, developed in accordance with the Istanbul Protocol, are filled out incompletely and incorrectly. In most cases, the documents only indicate that the injury was received during or after arrest, but do not indicate the methods of receiving the injury; the graphic images do not indicate the location of the injury; they do not assess the degree of consistency between the information provided by the prisoner and the objective data. Confidential environment: The lack of opportunity for a confidential meeting between doctors and prisoners hampers the detection of alleged violence. Although prison staff is allowed to attend the medical examination of a prisoner only in exceptional cases,75 as the practice in prisons and closed Information provided by the untried persons to the medical staff served as the basis for the documentation in all 3 cases. 71 See the report of the monitoring visits paid to Penitentiary Establishments Nos. 2, 8, 14 and 15, p. 13, available at:< https://bit.ly/39dU8e2 > [last accessed: 27.02.2020]. 72 Letter N370709/01 of the Special Penitentiary Service of the Ministry of Justice of Georgia, December 12, 2019. 73 For example, the influence of subculture (according to the informal rules established in the facilities, the victim of violence should not expose the infliction of injury and especially its causes) and distrust of victims of violence towards the investigative bodies. 74 However, according to them, 3-day training was provided for all doctors in 2017. 75 According to Article 3 (2) of the rules approved by Order No. 131 of the Minister of Corrections on October 26, 2016, “The presence of the third party at the examination is inadmissible. If the doctor deems the presence of prison staff necessary for his/her or patient's safety, the medical examination shall be conducted only under visual supervision of the relevant staff, without them being able to hear the content of the examination." 41