VIII)  Permanently unemployable convicts Established case law of the ECtHR lays down substantial requirements for imprisonment of convicts with mental retardation or other mental disorders and their accommodation. 102 There are three basic requirements following from the Convention: the convicts must be placed in a facility where psychiatric care is available on a daily basis 103; locking people up in their cells is an aggravating circumstance 104; convicts must be kept in a place which permits achieving the purpose of imprisonment. 105 I recommend that the Ministry of Justice: •• Pays due attention to convicts with mental illness in implementing the prisons strategy. 3) Material and personal hygiene conditions Imprisonment of PUCs entails high requirements for the material conditions and equipment of prisons, especially in case of immobile convicts. I consider the material conditions of imprisonment in the specialised blocks as generally unsatisfactory. This is the case mainly because of the significant lack of non-barrier elements in prisons that results from their age and design. The needs of immobile convicts are very specific and cannot be compared to the needs of ordinary prisoners. One of the shortcomings I noted was the absence of emergency alarms in the bedrooms of immobile convicts, not even next to the beds and in showers. Convicts reliant on the assistance of others were thus unable to call for help in case of need. I am especially concerned by this in relation to convicts with serious disabilities. At least in two individual cases 106 involving convicts demonstrably reliant on the help of others in their basic everyday tasks, the emergency alarm was placed beyond the convict’s reach from the bed (in the corridor) and was thus useless. I consider such practice to be completely inappropriate. convicts’ showers 102 Cf. especially the judgements of the European Court of Human Rights in case Rivière v. France; Sławomir Musiat v. Poland of 5 June 2009, no. 28300/06; G. v. France; and judgements in cases L. B. v. Belgium; Swennen v. Belgium of 10 January 2013, no. 53448/10; Lankester v. Belgium of 9 January2014, no. 22283/10. 103 If suitable psychiatric care is not available, this represents a risk to health which unavoidably leads to distress or hardship of an intensity exceeding the unavoidable level of suffering inherent in detention. For more details, see judgements in cases Sławomir Musiat v. Poland, Rivière v France, and G. v. France. 104 For more details, see judgement of the European Court of Human Rights in case Canali v. France of 25 April 2013, no. 40119/09. 105 For more details, see judgements in cases L. B. v. Belgium and Swennen v. Belgium. 106 A prisoner suffering from triparesis, i.e. paralysis of one upper and two lower limbs, was being locked up in his bedroom during silent hours without an emergency alarm in reach. The only way for him to call in help was to shout, but only people with the key could get to him. Prison employees were not commonly present in the corridor, which meant the convict was left to rely on his voice and the attention and willingness of people passing by (File No. 7624/2013/VOP/MS). /36/