-16 and among detainees whom they are most likely to affect. In a number of judgments against different Council of Europe member states, the European Court of Human Rights (ECtHR) held that prisoners are persons in a vulnerable situation and that the authorities are under a duty to protect them.9 Prisoners are vulnerable because they are isolated from society and from their networks of support, and are in the hands of the authorities who can exercise a significant amount of control on them in their daily lives. Their access to legal assistance is limited, as is their right to recourse to an independent authority to adjudicate their complaints. They are in a disadvantaged position in judicial proceedings in which they, unlike the prosecution, have very limited ability to collect and present evidence. In the June 2020 EU Strategy on victims’ rights (20202025), victims of crime committed in detention are referred to as a group in a situation of particular vulnerability.10 Even though prisoners are themselves a group in a situation of vulnerability, international standards refer to groups among prisoners who are in specifically vulnerable situations and provide for their special treatment to meet their specific needs. Rule 2 of the UN Standard Minimum Rules for the Treatment of Prisoners (SMR, Nelson Mandela Rules) states that “prison authorities shall take account of the individual needs of prisoners, in particular the most vulnerable categories in prison settings. Measures to protect and promote the rights of prisoners with special needs are required and shall not be regarded as discriminatory”.11 We can define prisoners in a situation of vulnerability as those who, due to their characteristics, real or attributed, social attitudes and the conditions of their detention, are at a higher risk than ordinary prisoners 9. See e.g.: ECtHR, Trubnikov v. Russia, no. 49790/99, Judgment of 5 July 2005, § 68. See also: CEDH, Berktay c. Turquie, no. 22493/93, Arrêt du 1 mars 2001, § 167; CEDH, Algür c. Turquie, no. 32574/96, Arrêt du 22 octobre 2002, § 44; CEDH, Mikadze c. Russie, no. 52697/99, Arrêt du 7 June 2007, § 109; ECtHR, Renolde v. France, no. 5608/05, Judgment of 16 October 2008, § 83; CEDH, Aliev c. Géorgie, no. 522/04, Arrêt du 13 janvier 2009, § 97. 10. European Commission, EU Strategy on victims’ rights (2020-2025), COM(2020) 258, Brussels, 24.6.2020, p. 14. 11. United Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules), Resolution adopted by the General Assembly on 17 December 2015.