the HRC, the CAT also makes direct reference to the Standard Minimum Rules for the Treatment of Prisoners, recommending that States end all practices that are contrary to these rules.186 The issue of solitary confinement is addressed by the HRC and the CAT, and is also covered by other international guidelines and recommendations. Principle 7 of the Basic Principles for the Treatment of Prisoners, for example, provides that “Efforts addressed to the abolition of solitary confinement as a punishment, or to the restriction of its use, should be undertaken and encouraged.” UN TREATY BODIES 1.3.4 Solitary confinement 1 – ICCPR In its General Comment No. 20, the HRC stated that prolonged solitary confinement may violate Article 7.187 In its Concluding Observations on the report of Denmark in 2000, the Committee expressed the view that “solitary confinement is a harsh penalty with serious psychological consequences and is justifiable only in case of urgent need; the use of solitary confinement other than in exceptional circumstances and for limited periods is inconsistent with article 10, paragraph 1, of the Covenant.”188 Therefore, if solitary confinement is not justified in the circumstances of the case, it will violate Article 10(1), and if it is for a prolonged period, it will in any case violate Article 7. In Polay Campos v Peru, a period of nine months of solitary confinement during pre-trial detention was found by the Committee to amount to a violation of Article 10(1) ICCPR, and the later “total isolation of Mr. Polay Campos for a period of a year and the restrictions placed on correspondence between him and his family constitute[d] inhuman treatment within the meaning of Article 7,”189 as well as violating Article 10(1). Not all instances of solitary confinement will violate the Covenant, however. In Vuolanne v Finland, the author was placed in solitary confinement for a total of 10 days as punishment for being absent without leave during his military servDoc. CAT/C/CR/30/7, 2003; Concluding Observations on the Russian Federation, UN Doc. CAT/C/CR/28/4, 2002, especially §6(i) which explicitly categorises the conditions of detention of children in institutions as inhuman or degrading. 186 See, for example, CAT, Concluding Observations on the Democratic Republic of the Congo, UN Doc. CAT/C/DRC/CO/1, 2006, §11; CAT, Concluding Observations on Togo, UN Doc. CAT/C/TGO/CO/1, 2006, §19. 187 HRC, General Comment No. 20, 1992, §6. 188 HRC, Concluding Observations on Denmark, UN Doc. CCPR/CO/70/DNK, 2000, §12. 189 Polay Campos v Peru, HRC Communication No. 577/1994, 6 November 1997, §8.6. 41