been trying to communicate with other prisoners shouting from his cell – something that is a natural behavior for a human being as a social individual. The negative effects resulting from K.G.’s long-term isolation were clearly visible during the meeting of the Public Defender’s trustee with him. Prisoner K.G. has been disciplined and ordered to isolation in avoidance of the rules and procedures prescribed by the Georgian legislation – a fact that itself amounts to unlawful limitation of his rights. Also, it is unclear how long the disciplinary measure should last or what exactly should happen (what criteria should be fulfilled) for the measure to become unnecessary and to be lifted. Likewise, it is unclear what makes the objective referred to by the director of the Institution no. 7 – the need to ensure security – impossible to achieve by moving K.G. to another cell where there are other inmates or to some other institution where his life and health would not be endangered. Having reviewed K.G.’s case, the Public Defender addressed the Minister of Corrections with its recommendation but, nevertheless, the prisoner remains alone in the cell, subjected to electronic surveillance. 2.3.6.3.  USE OF SPECIAL MEANS The European Court of Human Rights as well as the European Committee for the Prevention of Torture have developed a specific approach and standards concerning special means that can be used by law enforcement agents in maintaining public order. While draft amendments to the legislation on the use of special means were under consideration, the Public Defender produced its recommendations about the draft amendments. A majority of the Public Defender’s recommendations have been taken into account and have been reflected in the Imprisonment Code. Below we give an account of recommendations that have not been agreed with but that the Public Defender believes must become part of the Imprisonment Code and of the relevant bylaws. TEAR GAS AND PEPPER SPRAY The Code of Imprisonment has been amended by adding paragraphs “d” and “e” to Article 571, which allow for using tear gas and pepper spray against remand prisoners and sentenced prisoners. The European Court of Human Rights has a clear approach toward use of such gases by the law enforcement agents. According to the standard established by the European Court, these substances should not be used in confined spaces. Even when used in open spaces, the European Court concurs with the European Committee for the Prevention of Torture in that there should be clearly defined safeguards in place. In Ali Güneş v. Turkey, 69 in regard to use of pepper spray and tear gas, the Court has 69 Ali Güneş v. Turkey, no. 9829/07. 48 NATIONAL PREVENTIVE MECHANISM OF GEORGIA