A/HRC/25/60/Add.1 33. Section 22, paragraph 1, of the Prisons Service Act provides that a prisoner can make a complaint of assault, maltreatment or intimidation by a prison officer, or neglect or non-performance of duties or other misconduct. The complaint is submitted to the block commander, Director or officer-in-charge of the prison and passed up the chain of command to the regional level and then on to the then Acting Director-General of the Prisons Service under the Ministry of the Interior. According to the Government, only three complaints have been received at the highest level; they involved prisoner-onprisoner violence and were immediately investigated and appropriate sanctions imposed. There have been no complaints about treatment by prison staff. With nearly 15,000 prisoners living in oppressive conditions under authorities who also work in a difficult environment, the number of complaints seems surprisingly low. Lack of effective investigation of allegations of torture 34. The Special Rapporteur noted during interviews with detainees that, even when there were allegations of police brutality or use of excessive force, there was a general reluctance to complain and, as a result, few cases appear to have been investigated. 35. During his meeting with the Police Service, the Special Rapporteur was not provided with recent statistical data on allegations of torture and ill-treatment and on the results of any investigations undertaken in respect of law enforcement (CAT/C/GHA/1, paras. 66–75). There was also a lack of information concerning personnel who may be responsible for an offence under section 25 of the Prisons Service Act. It appears that few investigations are conducted and officials are seldom prosecuted. Burden of proof and independent medical examinations 36. There is a forensic laboratory in Accra under the authority of the Criminal Investigation Department and the Government reported that it was satisfied with the level of forensic expertise. However, the Special Rapporteur notes the absence of routine medical examinations by qualified forensic medical doctors at the police investigation stage, by court order or upon admission to prison. He is also concerned about sections 10– 13 of Police Service instruction 171, which provide for medical examinations to be conducted under the control of government medical officers and in the presence of a police officer during supposedly independent medical examinations. Medical assessments requested for forensic purposes are performed by medical staff who have no specific competence in forensic medicine. Monitoring and inspection of places of detention 37. In accordance with articles 2 and 16 of the Convention against Torture and Other Cruel Inhuman or Degrading Treatment or Punishment, the Government is obliged to prevent acts of torture and other cruel, inhuman or degrading treatment or punishment. The Commission on Human Rights and Administrative Justice does some prison monitoring, but does not currently receive adequate funding to conduct extensive monitoring. Some national NGOs have a limited monitoring and reporting role, subject to resources. 38. The Police Intelligence and Professional Standards Bureau is mandated to visit police stations to check on those detained in police custody and their treatment by personnel (A/HRC/WG6.14/GHA/1, para. 109) but neither the frequency nor the findings of such visits were ascertained. Ratification of the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment 39. The Special Rapporteur welcomes the commitment of the Government of Ghana to ratifying the Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment (Ibid., para. 101). In 2009, the 8