asylum-seekers arrested in accordance with Article 9.2 of the Law of Georgia on International Protection can be placed in the centre.171 In the reports published in 2015-2017, the Public Defender issued the following recommendations for the protection of persons placed in the TAC from ill-treatment and improvement of their living conditions: 11 recommendations were made to the Ministry of Internal Affairs of Georgia; 1 proposal was made to the Parliament of Georgia and 1 recommendation was made to the Government of Georgia. 1 out of the 11 recommendations made to the Ministry of Internal Affairs has been fulfilled; 2 recommendations have been fulfilled partially and 8 recommendations have not been fulfilled. The proposal made to the Parliament of Georgia and the recommendation to the Government of Georgia has not been fulfilled. The monitoring findings of the Special Preventive Group are given in the chapters below. 4.1. ALTERNATIVE MEASURES TO PLACEMENT IN THE TAC Under international human rights law, the right to liberty and security of person has paramount importance. No one shall be subjected to arbitrary arrest or detention. No one shall be deprived of their liberty except on the grounds and procedures established by law.172 It is important to apply these principles to migrants, among others, especially to asylum seekers who, by virtue of their status, are not persons accused of committing a crime.173 In the view of the United Nations Special Rapporteur on the human rights of migrants, the obligation to always consider alternatives to detention (non-custodial measures) before resorting to detention should be established by law. Detailed guidelines and proper training should be developed for judges and other state officials, such as police, border and immigration officers, in order to ensure a systematic application of non-custodial measures instead of detention.174 Detention of migrants should only be used as a last resort and only after less restrictive alternatives have been found to be unsuitable in the individual case considered. It may be important to consider whether detention is being used as a last resort, or if it is being used in an automatic fashion.175 171 The Law of Georgia on International Protection, Article 9. International Covenant on Civil and Political Rights, Article 9(1); International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families, Article 16(4); Convention for the Protection of Human Rights and Fundamental Freedoms, Article 5. 173 Under the legislation concerning refugees and international human rights law, arrest of asylum seekers must be considered a last resort. 174 Report of the Special Rapporteur on the human rights of migrants, para. 53, 2 April 2012, A/HRC/20/24. 175 Visiting Immigration Centres: A Guide for Parliamentarians, p. 28, the Council of Europe (2013), available at : http://tiny.cc/hies8y, (accessed 10.04.19). 172 68