meters. It follows that we should subtract 5,2 (1,3X4) square meters as well as roughly 1 square meter occupied by toilettes and tables amounting to a total of 8.3 square meters from the total area of each cell for eight people. It follows that even if only 4 prisoners are accommodated in a cell for eight people, the actual area usable by prisoners is narrow enough. The same is true for cells designed for four people. In assessing living conditions in the light of Article 3 of the European Convention on Human Rights, the European Court takes into consideration, in addition to personal space allocated to a prisoner, other aspects of physical conditions of detention, such as the possibility of outdoor exercise, access to natural light, availability of natural and artificial ventilation, adequacy of heating arrangements, the possibility of using the toilet with respect for privacy, and compliance with basic sanitation requirements.88 In Peers v. Greece, the Court deemed that the fact that two prisoners shared 7 square meters coupled with the lack of ventilation and daylight amounted to violation of Article 3 of the European Convention on Human Rights.89 The cells in the Institution have small-size windows (75x43 cm) covered with several layers of iron bars making the entry of air and sun beams into the cells virtually impossible. The institution’s ventilation system does not allow for sufficient movement of fresh air. Damp cells are ill lit and insufficiently heated. According to Article 15(4) of the Code of Imprisonment, the premises where remand prisoners and convicted prisoners are accommodated must have windows to ensure access to natural light and ventilation. Prisoners must be provided with heating as well. Pursuant to Rules 10 and 11 of the Standard Minimum Rules for the Treatment of Prisoners adopted in Geneva in 1955, all accommodation provided for the use of prisoners and in particular all sleeping accommodation shall meet all requirements of health, due regard being paid to climatic conditions and particularly to cubic content of air, minimum floor space, lighting, heating and ventilation. The windows shall be large enough to enable the prisoners to read or work by natural light, and shall be so constructed that they can allow the entrance of fresh air whether or not there is artificial ventilation. We would like to mention here that recently there has been a plan to install new windows in the penitentiary institution no. 7. These windows would not open and the cell would only be aired by artificial ventilation. On 16 December 2013 the Public Defender addressed a recommendation to the Minister Corrections stressing that even if artificial ventilation system would be provided, such a system could not substitute the need for fresh air intake in the cells. Accordingly, the Public Defender’s recommendation was to take account of domestic 88 89 Vlasov v. Russia, no. 78146/01, § 84, 12 June 2008; Trepashkin v. Russia, no. 36898/03, § 94, 19 July 2007. Peers v. Greece, judgment of 19 April, 2001, application no. 28524/95, § 70-72. 56 NATIONAL PREVENTIVE MECHANISM OF GEORGIA