VIII)  Permanently unemployable convicts problems and prevention of further deterioration of medical condition. 89 It should also be noted that the duty to provide adequate care includes rehabilitation care ordered by a physician. 90 In relation to the material living conditions of persons with disabilities, the ECtHR stresses that the States must adopt adequate modifications and remove all environmental obstacles preventing these persons from integration with the fellow convicts, and to the maximum possible degree promote their physical and psychological integrity, strengthen their autonomy and prevent their further stigmatisation. 91 This means removal of, in particular, all structural-technical obstacles preventing these persons from ECtHR building in Strasbourg independent movement in the parts of the prison where they would be able to stay if it was not for their disability. 92 Concerning respect for human dignity, ECtHR assigns special importance to ensuring independent access to and technical adjustment of toilets and showers to ensure that persons with disabilities can, if they are capable, perform these intimate tasks independently without help of others. Simultaneously, the State is obliged to enable incontinent persons to access the showers every day. 93 Concerning the provision of day care for persons with disabilities, the ECtHR stresses that the States cannot absolve itself of this duty by transferring it to the other convicts. 94 If these persons need it, the State must get them professional care provided by persons with the required qualification or training, who will receive compensation for their services from the State. Only everyday tasks not requiring any professional qualifications (e.g. small help with putting on clothes etc.) can be performed by unqualified personnel. 95 With respect to persons with mental illness, ECtHR has consistently ruled that these persons should be provided with daily psychiatric care if their medical condition requires it. If such care is not available, this represents a risk to health which, according to the ECtHR, unavoidably leads to distress or hardship of an intensity exceeding the unavoidable level of suffering inherent in detention. 96 In placing and keeping these persons in cells, regard must be had for the fact that they do not cope well with closed and overcrowded rooms due to their medical condition and, therefore, must be provided with increased personal space and the possibility to stay outside of the cell. 97 The ECtHR also stresses that these persons can only be kept in such structural and therapeutic environment that enables the achieving of the purpose of imprisonment. 98 The competent bodies are also obliged to adopt all the 89 E.g. judgement of the European Court of Human Rights in case lacov Stanciu v. Romania of 24 July 2012, no. 35972/05. 90 E.g. judgement of the European Court of Human Rights in case Helhal v. France of 19 February 2015, no. 10401/12. 91 E.g. judgement of the European Court of Human Rights in case Semikhvostov v. Russia of 6 February 2014, no. 2689/12. 92 E.g. judgement of the European Court of Human Rights in case Cara-Damiani v. Italy of 7 February 2012, no. 2447/05. 93 E.g. judgement of the European Court of Human Rights in case D. G. v. Poland of 12 February 2013, no. 45705/07. 94 E.g. judgement of the European Court of Human Rights in case Semikhvostov v. Russia of 6 February 2014, no. 2689/12. 95 E.g. judgement of the European Court of Human Rights in case Zarzycki v. Poland of 12 March 2013, no. 15351/03. 96 E.g. judgement of the European Court of Human Rights in case Rivière v. France of 11 July 2006, no. 33834/03;Sławomir Musiat v. Poland of 20 January 2009, no. 28300/06; and G. v. France of 23 February 2012, no. 27244/09. 97 E.g. Sławomir Musiat v. Poland. 98 E.g. judgement of the European Court of Human Rights in case K. B. v. Belgium of 2 October 2012, no. 22831/08. /34/

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