been applied in the interests of keeping the prisoner safe. However, the measure has not been ordered in compliance with Article 69 of the institution’s statute approved by the Order of the Minister of Corrections and Legal Assistance no. 97 dated 30 May 2011. This means the prisoner cannot enjoy the legal guarantees protecting him from violation of his rights by extended isolation. Here we would like to stress the approach developed by the European Court that States are obliged to periodically review the necessity and proportionality of a measure applied to a prisoner for security reasons. According to Rule 51.5 of the European Prison Rules, the level of security necessary shall be reviewed at regular intervals throughout a person’s imprisonment. In Ramirez Sanchez v. France, the European Court of Human Rights explained that solitary confinement cannot be imposed on a prisoner indefinitely. Moreover, it is essential that the prisoner should be able to have an independent judicial authority review the merits of and reasons for a prolonged measure of solitary confinement. The Court found violation of Article 13 because the prisoners in solitary confinement did not have any remedy available to challenge the original measure or any renewal of it.65 In Piechowicz v. Poland, the Court found a violation of Articles 3 and 8 of the Convention because the prisoner was held in isolation for a long time without having the chance to participate in any social activities with other prisoners. The Court also noted that all forms of solitary confinement without appropriate mental and physical stimulation deteriorates a person’s mental faculties and social abilities.66 The Court has been consistently stressing in many of its judgments that, under Article 3 of the Convention, the State must ensure that a person is detained in conditions which are compatible with respect for his human dignity, that the manner and method of the execution of the measure do not subject him to distress or hardship of an intensity exceeding the unavoidable level of suffering inherent in detention and that, given the practical demands of imprisonment, his health and well-being are adequately secured.67 The Court has also mentioned that when assessing conditions of detention, account has to be taken of the cumulative effects of these conditions, as well as of specific allegations made by the applicant.68 In the Institution no. 7, sentenced prisoner K.G. lacks the possibility of socializing. He has been repeatedly indicating that he does not feel safe. He does not have a TV set in his cell. During his time in isolation, he has been imposed disciplinary measures several times, which restricted his ability to communicate with the outside world. It should be mentioned that a major reason why he has been disciplined is that he has 65 66 67 68 Ramirez Sanchez v. France, no. 59450/00, § 145, 152. Piechowicz v. Poland, no. 20071/07, § 173. Valašinas v. Lithuania, no. 44558/98, § 102, ECHR 2001-VIII; see also Kudla v. Poland [GC], no. 30210/96, § 94, ECHR 2000-XI. Dougoz v. Greece, no. 40907/98, § 46, ECHR 2001-II. NATIONAL PREVENTIVE MECHANISM OF GEORGIA 47