records of inmates and detainees in the penitentiary system should be implemented. The check in the Traumatic Injuries Register shows no recorded injuries of detainees caused by wardens and guards of the detention facility. 7. Vidin Detention Facility During previous inspections of the detention facility in the city of Vidin, the NPM found that the premises lacked heating and sanitary units. Maybe this is the only detention facility in Bulgaria where one side of the building is used for detainees, and the other part is used for office premises. A design for the reorganisation of the detention facility has been prepared. By a letter of 28.05.2008 Vidin Municipality wrote to the minister of regional development, the minister of justice and the minister of interior with the question which institution was competent to grant authorisation for the reorganisation of the detention facility due to absent deed of state ownership. During the transfer of detention facilities from National Investigation Service to the Ministry of Justice, partition protocols were drawn up under § 74 of the Transitional Provisions of the Judicial System Act but no deeds of state ownership for the buildings of the Ministry of Interior (MoI) were issued. For this reason and in view of the redundant need in 2006, by a decision of the Council of Ministers the buildings were returned from MoJ to MoI without the necessary deeds and sketches. In the specific case of this detention facility, when there were available budgeted funds for reorganisatioin there was no consent by MoI. Later on there was consent by MoI but there were no budgeted funds for MoJ. Obviously this problem could compromise any Investment Programme under which a detention facility of MoJ is located in a building of MoI. The GDEP has granted official capacity to this detention facility in compliance with the required 4 sq. m. for 23 persons. In practice the facility supports 31 beds. This is required to meet the need of beds in peak loads as in August 2018 when there were 38 detainees. Given the location of the detention facility, many foreigners were detained and their maximum number was 14. At the time of the visit in 2019, there were 26 detainees, i.e. the facility was overcrowded. The NPM recommends relocation of the detention facility. The NPM reports considerable setbacks in detention facilities located outside prison areas. Where such detention facilities are concerned, GDEP always refers to the lack of capital expenditure. The NPM again reminds that the lack of financial resources is no justification for violation of fundamental human rights and freedoms. The NPM recommends to the Director General of the DG Execution of Punishments to prepare a programme for the development of detention facilities and propose it to the Minister of Justice for deposition to the Council of Ministers with a view to earmarking the required budgetary funds in the draft state budget for the next years 8. Kardzhali Detention Facility The detention facility in the city of Kardzhali is located in the building of Kardzhali Regional Directorate of MoI. The detention facility has 10 rooms with 2 beds each, 1 room with one bed and 1 room for walk. The area of the small room is 4.96 sq. m. and 8.68 sq. m. of the other rooms. There is no direct daylight, no sanitary units and no outdoor area in the detention facility. On the day of the visit there were three detainees in the facility and the peak load according to a report provided by the GDEP to the NPM is seven detainees. The problem with the lack of daylight is partially resolved with installed bars in the living rooms. Regardless of the differences in the architecture as compared to other detention facilities, this one is well maintained and kept in good repair. 25