detention. There is thus considerable overlap between its jurisprudence in this area and that on incommunicado detention and enforced disappearances, which will be considered in section 3.3.5. Where the detention is in addition unlawful, the Court has held that “it is possible to infer, even when there is no other evidence in this respect, that the treatment received during solitary confinement is inhuman and degrading.”531 The Inter-American Commission has gone further than the Court, finding that solitary confinement constituted torture within the definition of the IACPPT in the specific circumstances of Lizardo Cabrera v Dominican Republic.532 In that case, the solitary confinement was deliberately imposed by State agents for the purpose of personal punishment, and included aggravating treatment De la Cruz Flores v Peru (2004), op. cit., §128; Urrutia v Guatemala (2003), op. cit., §87; BamacaVelásquez v Guatemala (2000), op. cit., §150; Miguel Castro-Castro Prison v Peru, IACHR (Series C) No. 160, judgement of 25 November 2006, §323. 528 Bamaca-Velásquez v Guatemala (2000), op. cit., §150. See also De la Cruz Flores v Peru (2004), op. cit., §129; Urrutia v Guatemala (2003), op. cit., §87; Castillo Petruzzi and Others v Peru (1999), op. cit., §195; Suárez-Rosero v Ecuador, IACHR (Series C) No. 35, judgement of 12 November 1997, §90; Miguel Castro-Castro Prison v Peru (2006), op. cit., §323. 529 Montero-Aranguren and Others v Venezuela (2006), op. cit., §94. The Inter-American Court specifically referred to other international instances in this regard, including the report of the UN Committee against Torture on Turkey, the UN Standard Minimum Rules for the Treatment of Prisoners, and the findings of the European Court in Mathew v the Netherlands (2005), op. cit. 530 Juvenile Reeducation Institute v Paraguay (2004), op. cit., §167. See also section 3.1.1 above. 531 Urrutia v Guatemala (2003), op. cit., §87. See also Sánchez v Honduras (2003), op. cit., §98; Bamaca-Velásquez v Guatemala (2000), op. cit., §150; Cantoral-Benavides v Peru (2000), op. cit., §§83, 84, 89; Gómez-Paquiyauri Brothers v Peru (2004), op. cit., §108. 532 Lizardo Cabrera v Dominican Republic (1998), op. cit. 3 The Inter-american Regional System The Court has held that “prolonged isolation and coercive solitary confinement are, in themselves, cruel and inhuman treatments, damaging to the person’s psychic and moral integrity and the right to respect of the dignity inherent to the human person.”527 In addition to the suffering inherent in solitary confinement, it places individuals “in a particularly vulnerable position, and increases the risk of aggression and arbitrary acts in detention centers.”528 Thus, in MonteroAranguren v Venezuela, the Court held that “solitary confinement cells must be used as disciplinary measures or for the protection of persons only during the time necessary and in strict compliance with the criteria of reasonability, necessity and legality,” and specifically stated that minimum standards for conditions of detention must still be met.529 Furthermore, even the threat of solitary confinement may be enough to constitute inhuman treatment under Article 5 of the ACHR.530 527 117