-39 physical environments, and assistance in the exercise of daily functions and rehabilitation. Article 14 CRPD, prohibiting arbitrary and unlawful deprivation of liberty of persons with disabilities, Article 15, prohibiting torture, inhuman and degrading treatment and Article 16, providing for the freedom from exploitation, violence and abuse, are particularly relevant to prisoners. So is Article 13 providing for the access to justice. In its guidelines on Article 14 (right to liberty and security of person), the CRPD Committee has stated that deprivation of liberty in criminal proceedings should only apply as a matter of last resort and when other diversion programmes, including restorative justice, are insufficient to deter future crime. The 2018 resolution of the Parliamentary Assembly of the Council of Europe goes an important step further in standard-setting by providing for adjustment of prison sentences or alternatives to imprisonment based on the defendant’s disability, in order to prevent imprisonment of persons whose condition is incompatible with detention.71 In such cases member states should consider systematically non-custodial pre-trial measures and sentences or compassionate release for disabled persons where relevant. The SMR contain specific rules on prisoners with mental disabilities and/or health conditions.72 They provide that prisoners who suffer from such conditions and for whom staying in prison would exacerbate their conditions, shall not be detained in prison. They also provide for adequate treatment and care for such prisoners in specialized facilities. The ECtHR has considered a number of cases of prisoners with disabilities and has found violations of the ECHR where they were or were in danger of being treated contrary to Article 3. Thus, in one of its early judgments in the case of Price v. the UK the ECtHR found a violation of Article 3 for holding a person with a serious physical disability in detention, albeit for a short period of time (see text box).73 Accessibility of the physical environment in the prison seems to be a serious factor, which the ECtHR 71. Parliamentary Assembly of the Council of Europe, Detainees with disabilities in Europe, Resolution 2223 (2018) 72. Nelson Mandela Rules, rules 109-110. 73. ECtHR, Price v. the United Kingdom, No. 33394/96, Judgment of 10 July 2001. See also: D.G. v. Poland, No. 45705/07, Judgment of 12 February 2013. Prisoners in a Situation of Vulnerability