105 is the point of departure for any analysis of the rights and treatment accorded to persons in pretrial detention. Therefore, taking into account that the natural purpose of this measure is to ensure appearance of defendants in criminal proceedings, it makes no sense not to allow persons in pretrial detention to exercise their right to vote. 275. In the same vein, the United Nations Human Rights Committee has been emphatic in establishing that “[p]ersons who are deprived of liberty but who have 370 371 not been convicted should not be excluded from exercising the right to vote.” 276. Consequently, in accordance with Article 23 of the American Convention and XX of the American Declaration, States must adopt the necessary legislative, administrative and judicial measures to ensure in practice that persons held in pretrial detention are able to exercise their right to vote under equal conditions to the rest of the electorate. 277. The Commission notes that OAS States are able to provide, without much difficulty, measures to ensure the effective enjoyment of the right to vote of all persons in pretrial detention. For example, in Ecuador, Article 62 of the 2008 Constitution expressly recognizes this right of unconvicted persons deprived of liberty and, since that provision went into effect, through the National Electoral Council and the Ministry of Justice, the State has made the exercise of that right possible in the elections of 2009 and 2013. In the 2013 elections, the number of votes cast by persons 372 in pretrial detention surpassed 8,900. 4. Solitary confinement and high security modules 278. With respect to solitary confinement, defined as the physical and social isolation of individuals confined to their cells from 22 to 24 hours a day, the InterAmerican Commission has established as a general criterion that it “shall only be permitted as a disposition of last resort and for a strictly limited time, when it is evident that it is necessary to ensure legitimate interests relating to the institution’s internal 370 UN, Human Rights Committee, General Comment No. 25: Participation in public affairs and the right to vote, approved at the 47th Session (1999), para. 14. In Compilation of General Comments and General Recommendations Adopted by Human Rights Treaty Bodies Volume I, HRI/GEN/1/Rev.9 (Vol.I) published on May 27, 2008, p. 262. 371 See also Council of Europe/Committee of Ministers Recommendation Rec(2006)13 on the use of remand in custody, the conditions in which it takes place and the provision of safeguards against abuse, approved on September 27, 2006, para. 39. 372 See, among other media stories, Hoy.Com.Ec, Unconvicted prisoners exercised their right to vote (Presos sin sentencia ejercieron su derecho al voto), February 15, 2013, available in Spanish at: http://www.hoy.com.ec/noticias-ecuador/presos-sin-sentencia-ejercieron-su-derecho-al-voto-574316.html; and América Economía, Non sentenced prisoners will vote early in Ecuador (Presos sin sentencia votarán por anticipado en Ecuador), February 14, 2013, available in Spanish at: http://www.americaeconomia.com/politica-sociedad/politica/presos-sin-sentencia-votaran-por-anticipadoen-comicios-en-ecuador