case is immediately sent from the Investigation Division of General Inspection Service of the Ministry of Justice and the Western Division of the Investigation Department to the Prosecutor's Office for further response80 and from November 1, 2019 - to the State Inspector's Office.81 The above is problematic since the Investigation Department of the Special Penitentiary Service, which is not an institutionally independent agency, acts as a mediator in this area. It is important that information about alleged ill-treatment identified by doctors be sent immediately and directly to an independent investigative body and not to the Investigation Department of the Ministry of Justice, which is institutionally linked to the Special Penitentiary Service. With regard to this, shortcomings remain in paragraph 1 of Article 6 of Order No. 131 of the Minister of Corrections of Georgia, according to which, in case of a suspicion of torture and ill-treatment, the doctor shall report the case to the Investigation Department of the Ministry of Justice. This regulation needs to be amended. In particular, if the alleged perpetrator of torture or ill-treatment is an employee of the Ministry of Internal Affairs or a penitentiary facility, or a member of an escort group or a representative of another investigative body, the doctor should report the case directly to the State Inspector's Office. According to the information provided by the Prosecutor General’s Office of Georgia, from January 1, 2019 to October 31, 2019, 12 notifications were received from penitentiary facilities relating to the documentation of alleged torture and other cruel, inhuman or degrading treatment of prisoners by doctors in accordance with the above-mentioned rules. According to the same information, the inquiry found no development of injuries as a result of torture and ill-treatment by an employee of the Ministry of Internal Affairs or other investigative bodies, or by an employee of the penitentiary facility. Therefore, no investigation has been launched into any of the cases.82 It is worth noting that according to the monitoring results of the Special Preventive Group, the investigation is not interested in obtaining the injury charts filled in by doctors. From 2017 to the period of the monitoring, the investigation had not obtained any documentation or photos taken in accordance with the Istanbul Protocol, while the cameras that were used to take photos of injuries were sealed on March 30, 2017 and remained so during the monitoring as well.83 Consequently, it is unclear to the Special Preventive Group how the Prosecutor's Office of Georgia established that the injuries had not been developed as a result of torture and ill-treatment committed by law enforcement officers without obtaining/reviewing the documentation filled in by doctors or photos taken by them. 80 According to letter No. 13/974 of the Prosecutor's Office of Georgia of January 10, 2020, from January 1, 2019 to November 30, 2019, investigations were launched in 19 criminal cases of alleged ill-treatment of prisoners by the staff of penitentiary facilities. Investigation is pending in all the above cases and no prosecution has been launched against any individual. 81 Letter No. 371652/01 of the Special Penitentiary Service of the Ministry of Justice of Georgia, December 13, 2019. 82 Letter No. 13/3295 of the Prosecutor's Office of Georgia, January 20, 2019. 83 July-August 2019. 43