both facts described above are a violation of the rights under Articles 21125 and 22126 of the Imprisonment Code of Georgia.127 According to information received from the penitentiary institutions of the Ministry of Corrections, in the period between 1 January and 31 December 2014, administrative detention was imposed on 4 sentenced prisoners: 3 prisoners in the institution no. 7 and 1 prisoner in the institution no. 15. The term of detention was 10 days in all the four cases. None of these prisoners challenged the detention before appellate courts. It should be mentioned that administrative detention was used only once in 2013. According to draft amendments to the Code of Imprisonment authored by the Ministry of Corrections by the end of 2014, a list of grounds on which basis administrative detention may be ordered will expand. In particular, the changes will make it possible to impose administrative detention for up to 90 days upon prisoners in specialrisk places of deprivation of liberty for the following violations: 1) disobedience or other resistance to an institution’s servant or other authorized person while they are performing their official duties; commission of willful conduct, which endangers the life and/or health of other person or infringement upon the honor or dignity of other person; 3) transmission of any information in an unlawful form from one cell to another or outside the institution. It should be noted that, for the same disciplinary misconduct described above, prisoners in other, lower risk institutions may be imposed solitary confinement128 for no more than 14 days129 and administrative detention for up to 60 days may be used only if the prisoner commits another disciplinary misconduct while he/she is still serving punishment for the previous misconduct. So it is clear that the only reason for punishing one and the same conduct with substantially different sanctions is the prisoner’s risk status (special risk prisoners). Also, it is hard to understand why the objective of maintaining order and security in a penitentiary institution cannot be achieved in special-risk places of deprivation of liberty with sanctions under Article 80 of the Imprisonment Code. It is further surprising why administrative detention is considered more effective while its enforcement starts only after the sentence indicated in the convicting judgment has been served; why would it not be more effective to use disciplinary sanctions that are enforceable immediately. So, it is clear that the proposed 125 The Imprisonment Code, Article 21: 1. An accused/sentenced person shall have the possibility to satisfy his/her physiological needs and maintain his/her personal hygiene in manner that does not affect his/her honor and dignity. 2. Normally accused/sentenced persons should be provided with the possibility to take shower twice a week and to visit a hairdresser at least once a month. It is prohibited for the administration to have an accused/sentenced person shave his/her head completely unless a doctor requests so or this is necessary for hygienic reasons. 126 The Imprisonment Code, Article 22(3): A prisoner must have a bed and linen in his/her personal possession, which he/she should receive in an clean and undamaged condition. The administration must ensure that the linen is clean. 127 Ibid. 128 Under Article 88(1) of the Imprisonment Code, solitary confinement as a disciplinary sanction should be used only in special cases. 129 The draft changes propose reduction of the duration of solitary detention from 20 days to 14 days – a change we certainly welcome. 78 NATIONAL PREVENTIVE MECHANISM OF GEORGIA