-41 was committed to prison for seven days because she refused to answer questions put to her concerning her financial situation. Because her case had been heard during the afternoon, it was not possible to take her to prison until the next day and she spent the night in a cell in a police station. The cell, which contained a wooden bed and a mattress, was not specially adapted for a disabled person. The applicant alleged that she was forced to sleep in her wheelchair; that the emergency buttons and light switches were out of her reach; and that she was unable to use the toilet since it was higher than her wheelchair and therefore inaccessible. During her detention in the police cell, the custody record showed that she was complaining of the cold. No action was taken by the police officers responsible for the applicant’s custody to ensure that she was removed to a more suitable place of detention or released. Instead, she had to remain in the cell all night, although the doctor did wrap her in a space blanket and give her some painkillers. The ECtHR considered that the detainment of a severely disabled person in conditions where she was dangerously cold, increased the risk of developing sores because her bed was too hard or unreachable, and was unable to go to the toilet or keep clean without the greatest of difficulty. As such, this constituted degrading treatment contrary to Article 3 ECHR. The EU recommendation on vulnerable persons80 focuses on suspects or accused persons who are not able to understand and to effectively participate in criminal proceedings due to age, mental or physical conditions or disabilities. Article 14 of the Charter recommends that member states take all steps to ensure that deprivation of liberty of vulnerable persons before their conviction is a measure of last resort, proportionate, and taking place under conditions suited to their needs. It mentions specifically the need to take appropriate measures in order to ensure that vulnerable persons have access to reasonable accommodations when deprived of liberty.81 80. Commission Recommendation of 27 November 2013 on procedural safeguards for vulnerable persons suspected or accused in criminal proceedings, OJ C 378, 24.12.2013. 81. For more information on the implementation of the recommendation in several member states see: BIM, Dignity at Trial: Enhancing procedural safeguards for suspects with intellectual and psychosocial disabilities, project documents available at: https://bim.lbg.ac.at/en/project/current-projects-projectshuman-dignity-and-public-security-projects-development-cooperation-and-business/dignitytrial-enhancing-procedural-safeguards-suspects-intellectual-and-psychosocial-disabilities, accessed 1 October 2020. Prisoners in a Situation of Vulnerability