A/HRC/13/39/Add.2 99. The Special Rapporteur is however seriously concerned about the greater vulnerability of minors to ill-treatment in police stations and consistent allegations of beatings after arrest, as well as the seemingly excessive use of force and collective punishment after riots and rebellions in detention facilities for minors. In addition, he is worried about the conditions of detention in these centres and the punitive approach of the administration of justice system for juvenile offenders, giving minors no opportunities for rehabilitation. 100. In general, the use of imprisonment as the first and not the last resort has not curbed the rates of criminality or prevented recidivism. On the contrary, the great majority of Uruguay’s prisons are severely overcrowded and the risk of a total collapse of the penitentiary system is real. The lack of an alternative concept poses a serious threat of insecurity, violence and deterioration of basic values that severely impacts society as a whole. 101. Whereas in recent years, some efforts have been made to improve overall conditions in prisons and prevent overcrowding, the conditions in certain wings of Libertad and COMCAR amount to inhuman and degrading treatment. The overcrowding and limited access to medical services is of concern in practically all the places he visited. There is an urgent need to move away from a punitive penal and penitentiary system directed at locking people up. A comprehensive reform of the whole administration of justice system, introducing a new approach aiming at the rehabilitation and reintegration of offenders in society, must be awarded the highest priority. 102. The Special Rapporteur welcomes Uruguay’s ratification of OPCAT and the recent adoption of a law establishing INDDHH, including an NPM. He hopes that the new institution will build on the work and expertise of the existing mechanism of the Parliamentary Commissioner to become the most effective means of preventing torture and ill-treatment in the future. 103. With regard to violence against women, the Special Rapporteur was pleased to hear about the creation of the National Action Plan on Fighting Domestic Violence and acknowledges that some first steps have been taken in this regard. He is however concerned about the delay in its full implementation, leading to a situation where preventive and protective measures afforded by the State are still inadequate. B. Recommendations 104. In the spirit of cooperation and partnership, and encouraged by the first measures taken shortly after his visit, the Special Rapporteur makes the following recommendations to the Government, aimed at preventing torture and ill-treatment and improving prison conditions. He is assured that every effort will be made to implement them and stands ready to offer his full cooperation and assistance in this regard. 105. Reform of the administration of criminal justice system: (a) Undertake a fundamental reform of the criminal justice and penitentiary systems aimed at the prevention of crime and the resocialization of offenders, rather than focusing on punitive measures and a policy of simply locking up suspected and convicted criminals; (b) Create a Ministry of Justice, responsible for the penitentiary system and encompassed within the framework of a comprehensive reform of the criminal justice system; 22 GE.09-17655