recommendation could be implemented only through an amendment to the criminal procedural legislation, which was beyond the authority of the Ministry. The Public Defender explained to the Ministry that the criminal procedure legislation allows the use of audio and/or video recording equipment during the Interviews and that there was no impediment to the implementation of this recommendation on the pilot basis.266 In a response sent in 2020, the Ministry presented a new reason to justify non-compliance with the recommendation. In particular, the Ministry's response states that the Ministry does not agree with the introduction in the legislation of the obligation to record the Interviews electronically and notes that there is no international act that would oblige any country to do so. In addition, the response states that there is no common approach to recording, not only at the international level, but also within countries, and that the definition of a recording obligation often depends on the type of crime and the perpetrator. Treaty based instruments created under international conventions, such as the Committee against Torture (CAT), the Subcommittee on Prevention of Torture (SPT) and the Council of Europe Committee for the Prevention of Torture (CPT), have a clear position on this issue. The European Committee for the Prevention of Torture recommends that Member States conduct continuous electronic (audio and/or video) interrogation of detainees at police stations, which is an important additional guarantee of protection against torture and ill-treatment.267 The Committee against Torture also recommended video recordings of all interrogations in its reports issued for the various countries.268 The annual report of the Special Rapporteur on Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, which was submitted to the General Assembly, also addresses this issue.269 As for the existence of a heterogeneous approach to the issue at national and international level, naturally there are countries where there is no obligation to record audio-video, however, the fact that the production of audio-video recordings is not introduced in some countries does not mean that the country is an example of good practice. As mentioned above, audio/video recording of the detention process is a standard recognized by the UN and Council of Europe treaties, and the obligation to provide safeguards derives from Article 2 of the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment. The Committee of Ministers of the Council of Europe in its decision on the Tsintsabadze Group case has called on the Government of Georgia to use audio-video recordings when law enforcement officials communicate with detainees and persons deprived of liberty.270 Criminal Procedure Code of Georgia, Article 113, Part 9. Report for the Government of Cyprus, European Committee for the Prevention of Torture, CPT/Inf (2018) 16, 26.04.2018, para.16, Report for the Government of Serbia, European Committee for the Prevention of Torture, CPT/Inf (2018) 21.06.18, para.41, information available on the following website: https://rm.coe.int/16808b5ee7 [Last visited 04.02.2021]; 268 The final report for the Russian Federation by the Committee against Torture, CAT/C/RUS/CO/6, 28.08.2018, available on the webpage: https://goo.gl/JYvzY2 [last visited 05.01.2021]; Final Report for Spain, Committee against Torture, CAT/C/ESP/CO/6, 29 May 2015, available at the webpage: https://goo.gl/gCjR69 [Last visited 04.01.2021]; 269Annual Report of the Special Rapporteur on UN Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment before the General Assembly, E/CN.4/2003/68, 17 December 2002, para. 26 (g). 270 Decision of the Committee of Ministers of the Council of Europe on the case of the Tsintsabadze Group, paragraph 13, available at the following address: https://bit.ly/3a5Q0jT [Last visited: 08.01.21]. 266 267 87