authorities to the satisfaction of the Committee of Ministers of the Council of Europe. Thus the action to be taken is a matter for the State in conjunction with the Committee of Ministers, for the European Court of Human Rights cannot dictate to a State the specific measures it should take. The primary level of protection for human rights is domestic. National courts are expected to ensure that European standards are reflected and applied in the decisions of national courts. Interfering with a prisoner’s right of complaint The right of victims of violations of ECHR guarantees to make use of their rights is also protected by the European Court of Human Rights under Article 34 of the ECHR. This provides that states “undertake not to hinder in any way the effective exercise of this right”. The control the state exercises over persons deprived of their liberty may allow officials the means to interfere with the right of petition, for example, through interference with a detainee’s correspondence or the bringing of pressure to withdraw a complaint through the threat of imposition of sanction. Recognition by the European Court of Human Rights of the vulnerability of prisoners is evident from cases such as Cotleţ v Romania. Here, a violation of Article 34 was established in light of the intimidation of the prisoner, the failure of the prison authorities to provide necessary writing materials for his correspondence with the European Court of Human Rights, and both the delay in forwarding and the systematic opening of the prisoner’s mail. All of this “constituted a form of illegal and unacceptable pressure which infringed the applicant’s right of individual application”, a conclusion “all the more imperative having regard to the particular vulnerability of the applicant who had few contacts with his close relatives or with the outside world while in custody”.2 1.2.2 Standard-setting by the CPT A European system which relies primarily upon individual complaint to secure effective compliance with human rights has inherent limitations on account of practical difficulties such as low levels of awareness amongst individuals and over-lengthy and costly procedural machinery. The CPT Convention reflects the recognition that protection of persons deprived of their liberty is often more effectively and efficiently protected by directing attention to the fundamental causes of ill-treatment rather than through the provision of a remedy for its infliction at some later stage. The body set up by an international treaty – the CPT - achieves its goal of enhancing protection for individuals through on-the-spot monitoring and the encouragement 2. Cotleţ v Romania (3 June 2003), para 71. European standard-setting ► Page 11