CAT/OP/POL/CNPMRO/1 apprehended persons or for intoxicated persons brought to sober up, on transitional facilities and police emergency centres for children, as well as on rules governing the stay in such facilities, and on the manner of dealing with image recordings from such rooms, centres and facilities. As a result of changes proposed by the CHR, a legislative amendment was introduced allowing a juvenile to have obligatory contact, upon his/her request, with a lawyer, a parent or a legal guardian. The CHR also proposed that a juvenile should be allowed to be visited and have a phone conversation in conditions ensuring privacy. Amendment is also required in legal regulations that provide for a possibility for a lawyer to contact a juvenile in a sobering-up facility, only upon the juvenile’s request. However, in the opinion of the Minister of the Interior and Administration, this remark need not be considered. • Opinion of 30 October 2016 on the draft act amending the Act on mental health protection and some other acts. The CHR pointed out, among others, that the amendment does not specify who is to control the condition of person who has been subjected to direct coercion. In view of pertinence of the issue, it would also be worth considering whether the manner of checking the physical condition of person with mental disorders who is immobilized or isolated, and the way of assessing if using such measures is justified, should be regulated in the Act on mental health protection. In the CHR’s opinion, all kinds of establishments (not only those intended for people with mental disorders, as is the case at present) should be subject to judicial supervision, since people with mental disorders are placed in various establishments, by decision of referring authority. • Opinion of 10 June 2019 on draft regulation of the Minister of Justice amending the regulation on youth correctional centres and juvenile shelters. The amendments proposed by the CHR were assessed very favourably. First of all, the amended regulation excludes the possibility of isolating juveniles in separate rooms without indicating specific reasons for doing so and without specifying the time frame. Such practice, as results from materials collected under the NMPT, was rather common. • Opinion on 14 March 2016 on draft regulation of the Minister of Justice amending the regulation on medical services provided by health entities to persons deprived of their liberty. The CHR pointed out that the amendment proposed in draft regulation would deprive representatives of prison health services of the possibility to take decisions to transport an inmate to an external heath service provider. The proposition to abandon the obligatory dental check of each person admitted to penitentiary establishment was also negatively assessed. Finally, the first proposal of the CHR was incorporated in the regulation. • Opinion of 30 June 2017 on the Council of Europe draft instrument to codify the Rules on the conditions of detention of migrants. The CHR raised reservations regarding: personal scope of application of the Rules, the manner of identification of victims of torture among foreigners in guarded centres, applying prisons rules towards people in administrative detention, and the admissibility of youth detention. • Opinion of 15 April 2019 on draft act on juveniles. The CHR prepared a comprehensive opinion on the draft act regulating proceedings in cases of depraved youth; the draft act is to replace the Act of 1982 on proceeding in juvenile cases currently functioning in this scope. • The Commissioner’s initiative engaging the Office for Democratic Institutions and Human Rights (ODIHR) in developing a comprehensive legal opinion based on a review of the Polish legislation, indicating that the crime of torture as such is not specified there, is also worth recalling. As a result, the CHR wrote to the Minister of Justice to suggest the inclusion of the crime of torture in the Polish Penal Code, and attached the said opinion of the ODIHR. 2. Obligations and visibility of the mechanism Comments on the recommendation(s) contained in paragraph 35 52. In December 2018, the Commissioner, together with the Council of Europe, launched the State without torture social campaign. Within its framework, the National 11