issue of relations and dialogue with the National Preventive Mechanism of the Special Penitentiary Service of the Ministry of Justice was mentioned in the content of the plan, as in recent years the Ministry of Justice has not conducted constructive dialogue, which is a violation of the obligation under the Optional Protocol to the Convention against Torture, Inhuman or Degrading Treatment or Punishment511. It is unfortunate that this issue was not included in the action plan. One of the activities of the Action Plan was to strengthen measures to prevent violence among persons placed in detention facilities, although no specific actions were given on how to strengthen measures to prevent violence. In the opinion of the Public Defender, it would be important to put the recommendations in the Action Plan, such as: developing a strategy to tackle the criminal subculture and informal ruling in penitentiary institutions and protecting victims of violence, including by transferring to other institutions or avoiding contact with inmates of criminal subcultures. The above recommendations are also given in the report of the European Committee for the Prevention of Torture following its visit to Georgia in 2018.512 In addition, they are reflected in the 2020 Parliament resolution.513 It is regrettable that these recommendations and the task given by the Parliament were not included in the Action Plan. One of the activities of the action plan was to strengthen measures to ensure the rehabilitation of persons in the penitentiary institution, activities outside the cell and contact with the outside world. In the opinion of the Public Defender, in order to strengthen the rehabilitation component in penitentiary institutions, it would be important to include in the plan recommendations №2, №8, №14 and №15 to by increasing their number, balance the number of social workers and psychologists in penitentiary institutions with the number of prisoners. In addition, the Public Defender demanded to include the activity reflecting the recommendation to allow prisoners in closed and special-risk facilities to stay in the fresh air for more than 1 hour. The above recommendations are also reflected in the 2020 Parliament resolution and the relevant task has been issued. It is unfortunate that these issues were not included in the action plan. In general, it can be said that the activities given in the Action Plan, as well as the indicators of the results of the activities are quite general, so it would be important to at least define the recommendations of the Public Defender as the output indicators of the activities, which would more accurately determine what measures would have to be taken by special penitentiary service to achieve the objectives and it would also make it possible to evaluate the performance later on. 6.2. Psychiatric institutions One of the activities of the Action Plan was to further improve existing internal regulatory and monitoring mechanisms for detecting, documenting and reporting of ill-treatment. In the opinion of the Public Defender, it would be important to include the following recommendations as the activities of the plan: Optional Protocol to the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, Article 22. 512 Report on the visit of the European Committee for the Prevention of Torture to Georgia (CPT/Inf (2019)16), para. 100, September 10-21, 2018, available in English at: https://rm.coe.int/1680945eca [Last visited: 20.01.21]. 513 Resolution of the Parliament of Georgia on the Report of the Public Defender of Georgia on the Situation of Human Rights and Freedoms in Georgia in 2019. 511 151