2.3.4 Solitary confinement In assessing whether solitary confinement falls within the ambit of Article 3 in a particular case, the Court will consider among other things the stringency of the measure, its duration, the objective pursued and its effects on the person concerned.390 Where conditions of detention comply with the Convention and the detainee has contact with the outside world, through visits and contact with prison staff, the prohibition of contact with other prisoners will not breach Article 3 provided that the regime is proportional to the aim to be achieved, and the period of solitary detention is not excessive. In its determination of whether the period is “excessive under Article 3 the Court [will]… take into account the conditions of the detention including the extent of the social isolation.”391 Thus, in Ramirez Sanchez v France, a period of more than eight years of solitary confinement was not found to be excessive, “having regard to the physical conditions of the applicant’s detention, the fact that his isolation is ‘relative,’ the authorities’ willingness to hold him under the ordinary regime, his character and the danger he poses,”392 whereas in Mathew v the Netherlands, a period of approximately 19 months was considered excessive in light of the poor conditions of detention and the health problems of the applicant.393 In the former case, the Court stressed the importance of safeguards to prevent arbitrariness, such as regular assessments of the continued necessity of the solitary detention and of the prisoner’s physical and mental health, as well as access to independent judicial review of the solitary confinement.394 Messina v Italy, op. cit. See, for example, Öcalan v Turkey, no. 46221/99, ECHR 2005-IV, judgement of 12 May 2005, §191; Valaainas v Lithuania (2001), op. cit., §112; Rohde v Denmark, no. 69332/01, judgement of 21 July 2005, §93. 390 Dhoest v Belgium, no. 10448/83, Commission report of 14 May 1987, §§ 117–18; McFeeley and Others v UK, no. 8317/78, Commission decision of 15 May 1980. 391 Rohde v Denmark (2005), op. cit., §97. 392 Ramirez Sanchez v France, no. 59450/00, judgement of 4 July 2006, §150. 393 Mathew v the Netherlands, no. 24919/03, ECHR 2005-IX, judgement of 29 September 2005. 394 Ramirez Sanchez v France (2006), §139–145. 2 The European Regional System The Court has held that complete sensory isolation, coupled with total social isolation, can destroy the personality and constitutes a form of inhuman treatment which cannot be justified by the requirements of security or any other reason. On the other hand, isolation from other prisoners for security, disciplinary or protective reasons does not in itself amount to inhuman treatment or degrading punishment.388 Thus, solitary confinement does not automatically violate Article 3.389 388 389 81