-37 choose their place of detention and that “separation of the applicant prisoner from his family and being kept at a distance from them are regarded as inevitable consequences of detention following the exercise by the domestic authorities of their prerogatives in the area of criminal sanctions”.67 Thus, in the view of the ECtHR, state parties’ “prerogatives in the area of criminal detention” take absolute precedence over prisoners’ Article 8 rights in cases of international transfer, with no possibility for balancing after an assessment of the specific circumstances of the case. Specific standards:68 • Convention on the Protection of the Rights of All Migrant Workers and Members of their Families, 18 December 1990 • Convention relating to the Status of Stateless Persons, 28 September 1954 • Convention on the Transfer of Sentenced Persons, 21 March 1983 • Recommendation Rec(2006)2 of the Committee of Ministers to member states on the European Prison Rules • Recommendation CM/Rec(2008)11 of the Committee of Ministers to member states on the European Rules for juvenile offenders subject to sanctions or measures • Recommendation CM/Rec(2012)12 of the Committee of Ministers to member States concerning foreign prisoners, Council of Europe, October 2012 • Council Framework Decision 2008/909/JHA of 27 November 2008 on the application of the principle of mutual recognition to judgments in criminal matters imposing custodial sentences or measures involving deprivation of liberty for the purpose of their enforcement in the European Union Additional Readings: • Monitoring Immigration Detention: A Practical Manual, United Nations High Commissioner for Refugees (UNHCR), 67. ECtHR, Palfreeman v. Bulgaria, No. 59779/14, Decision of 16 May 2017, § 36. This approach of the Court differs from its approach to placement of prisoners closer to their homes and families within the national jurisdiction, which it found to fall within Article 8 of the Convention in a number of cases. See e.g.: ECtHR, Khodorkovskiy and Lebedev v. Russia, Nos. 11082/06 and 13772/05, Judgment of 25 July 2013; ECtHR, Vintman v. Ukraine, No. 28403/05, Judgment of 23 October 2014; ECtHR, Rodzevillo v. Ukraine, No. 38771/05, Judgment of 14 January 2016. 68. For the texts of the relevant parts of some of the documents cited below see: https://www.apt.ch/ detention-focus/en/vulnerable_groups/2/, accessed 1 October 2020. Prisoners in a Situation of Vulnerability