Recommendation (A/HRC/16/52/Add.3) Situation during the visit (A/HRC/16/52/Add.3) Information received in the reporting period Morgan43 case. The legal position established by Pratt and Morgan prevented death row prisoners from being subjected to inhuman and degrading treatment by reason of: (a) the conditions under which persons sentenced to death are detained pending execution of the sentence; and (b) the length of time which elapses between the date on which the sentence is imposed and the date on which the sentence is executed. It is reported that the failure to ensure that individuals sentenced to death in Jamaica are able to seek the review of their sentence on the basis established by Pratt and Morgan constitutes the entrenchment within Jamaican Law of a provision within the Charter that is wholly inconsistent with the fundamental rights protected under the Covenant. 78. The Special Rapporteur also recommends that the relevant United Nations bodies, donor Governments and development agencies consider the administration of justice as the highest priority, in particular the fight against violent crime, policing and the penitentiary system. 145 Earl Pratt and Ivan Morgan v. The Attorney General for Jamaica et. al. (2 Nov. 1993). Privy Council Appeal No.10 of 993. A/HRC/19/61/Add.3 43 Further, it is reported that the de facto executions by police remains unacceptably high, with the number of those killed having increased to 320 in 2010 (not including the 73 confirmed killed during the State of Emergency). Reportedly, this now results in 1 in 5 of all killings in Jamaica occurring at the hands of the police.