the 2019-2020 Action Plan.77 At the same time, the Public Defender emphasizes that in order to reduce overloading, it is important to increase the number of staff in the penitentiary system, as well as to reduce the number of prisoners, including through the use of early release mechanisms, non-custodial sentences and preventive measures. 2.3.3.2. Informal ruling in Penitentary Establishments As in previous years, in 2020, informal ruling in penitentiary establishments remains a serious challenge in terms of protection of the prisoners from violence. Administrations of the establishments delegate power to informal leaders (so-called prison watchers) and through them informal ruling of penitentiary establishments is carried out, with the aim of silencing prisoners, banning them from talking about problems, and maintaining illusory order in the facilities. Informal ruling is characterized by physical and severe psychological violence among prisoners. Psychological violence is mainly manifested in extortion, humiliation, exclusion and other actions. As a result, a certain proportion of prisoners in a privileged position engage in informal ruling through repressive methods, which often leads to violence among prisoners and is manifested in the imposition of punitive measures on prisoners who do not obey the informal ruling. It is noteworthy that in the report published in 2019 the European Committee for the Prevention of Torture also points out the fact of delegating authority to informal leaders. The European Committee for the Prevention of Torture calls on the Georgian authorities to instruct the staff and management of Penitentiary Institution N15 to monitor closely and take all necessary measures to prevent and combat violence and intimidation among prisoners. These measures should include ongoing monitoring of prisoners' behavior (including the identification of alleged perpetrators and victims), appropriate documentation and reporting of confirmed and reported cases of intimidation/violence among inmates, and the investigation of all cases.78 As in 2019, during a monitoring in 2020, a special preventive team received information about physical and psychological abuse perpetrated by other inmates at the N8 penitentiary establishment. According to the information received, the facility had convicts close to the administration who have some influence over other inmates and, if necessary, the administration uses them to "resolve relations" with prisoners (in cases of hunger, appeals, other forms of dissatisfaction or conflict situations). Privileged inmates, unlike other inmates, move freely within the facility, control prisoners, enter cells, and physically assault disobeying inmates. In the 2019 report, the Public Defender noted that in the situation of the lacking of proper management of penitentiary institutions, the scale of informal ruling was slowly increasing, which was a significant risk factor for violence against prisoners and required a timely response. The Public Defender called on the Ministry of Justice of Georgia to develop a plan for the elimination of informal ruling and to carry out appropriate measures. Besides, the measures should be taken in the conditions of protection of the rights Available at the following address:< https://bit.ly/2T2d8qP > [last visited 18.01.2021] Report on the visit of the European Committee for the Prevention of Torture to Georgia on 10-21 September 2018 (CPT/Inf (2019) 16), para. 53, available in English at: < https://rm.coe.int/1680945eca> [last visited: 28.01.2021]. 77 78 42