Defender welcomes the reflection of a number of recommendations made by the National Preventive Mechanism in the Action Plan, however, it is unfortunate that a number of important, systematic recommendations have not been taken into account, including the recommendations adopted in accordance with the recommendations issued by the UN, Council of Europe and other international and regional treaties organizations. The Deputy Public Defender, at a remote meeting of the Interagency Coordination Council held for the approval of the Action Plan, assessed some of the activities included in the plan as progressive and expressed his desire to work closely with the Secretariat. Nevertheless, the Deputy Public Defender refrained from supporting the action plan because a number of important recommendations of the ombudsman had not been taken into account by the council. Below are some of the recommendations that were of the utmost importance, unfortunately, were not reflected in the plan. In the context of strengthening accountability mechanisms it is important to present an evaluation report on the implementation of the previous plan and introduce it to the members of the Interagency Coordination Council before developing a new action plan. This mechanism is important both in the context of accountability and in assessing the extent to which recommendations for the previous action plan have been taken into account, deficiencies corrected and improved. We also note that some of the objectives and activities envisaged by the plan are identical or otherwise formulated to the activities imposed on the relevant state agencies under the action plans of previous years. The 2021-2022 Action Plan repeats a number of activities of the 2019-2020 Action Plan to Combat Torture, Inhuman, Cruel or Inhuman or Degrading Treatment or Punishment. So for example: the 20192020 plan provided activity - on the obligations to report signs of ill-treatment, on further refinement of existing internal regulations and monitoring mechanisms. This activity is also included in the 2020-2021 Action Plan. This means that the country has not been able to fulfill the objectives set out in the action plan of previous years. Also, a number of activities that have not been implemented according to the information of the Public Defender have been removed from the 2020-2021 Action Plan or simplified, for example: აccording to the 2019-2020 plan, the Ministry of Internal Affairs should have developed a rule for the use of a body video camera by the patrol police in order to prevent and respond to violations. In the Action Plan for 2021-2020, the Ministry of Internal Affairs is responsible only for studying international practice in this regard. Therefore, in order for the current Action Plan for 2021-2022 to be realistic and feasible, it is necessary for the Coordination Council to examine why the commitments made in the Action Plans of previous years have not been fulfilled and to consider the results of the study in the Action Plan for 2021-2022. With this approach, it is possible to identify the circumstances that hindered the implementation of activities planned in previous years, and therefore, the current action plan should reflect the activities that will be aimed at eliminating the obstacles. 6.1. Penitentiary system One of the activities of the Action Plan was to support the activities of the National Preventive Mechanism and to strengthen existing cooperation. In the opinion of the Public Defender, it would be better if the 150