The Inter-american Regional System 3 inadequate food, inadequate physical activity, inadequate access to education or recreation, a lack of psychological or medical attention, and isolation or undue restrictions upon the visiting schedule constitute violations of the right to humane treatment under Article 5 of the ACHR.521 Furthermore, States have an obligation to ensure adequate medical attention to those in their custody, including facilitating examination of detainees by the doctor of their choice.522 In Montero-Aranguren v Venezuela, the Court emphasised that assistance by a doctor without links to the detention centre authorities constitutes “an important safeguard against torture and physical or mental ill-treatment of inmates.”523 Providing and ensuring adequate conditions of detention is an immediate obligation; “States cannot invoke economic hardships to justify imprisonment conditions that do not respect the inherent dignity of human beings.”524 In Berenson-Mejía v Peru, the Court explicitly related the conditions and the aims of detention, stating that conditions of detention which adversely affect the physical, mental and moral integrity of detainees are “contrary to the ‘essential aim’ of the penalty of imprisonment, as established in [Article 5(6) of the ACHR]; in other words, ‘the reform and social readaptation of the prisoners.’”525 Furthermore, the State must take measures to ensure that all detainees have the opportunity to “build their life plan, even while incarcerated.”526 3.3.4 Solitary confinement The Inter-American Court has adopted a wider definition than other international instances of the term ‘solitary confinement,’ using it to refer both to isolation of a detainee from others and to isolation resulting from illegal See, for example, Caesar v Trinidad and Tobago (2005), op. cit., §96; Raxcacó Reyes v Guatemala, IACHR (Series C) No. 134, judgement of 15 September 2005, §95; Berenson-Mejía v Peru (2004), op. cit., §102; Tibi v Ecuador (2004), op. cit., §150; Juvenile Reeducation Institute v Paraguay (2004), op. cit., §151; De la Cruz Flores v Peru (2004), op. cit., §130. See also the UN Standard Minimum Rules for the Treatment of Prisoners. 522 Tibi v Ecuador (2004), op. cit., §156; Juvenile Reeducation Institute v Paraguay (2004), op. cit., §157; Bulacio v Argentina (2003), op. cit., §131. See also Principle 24 of the Body of Principles for the Protection of All Persons Under Any Form of Detention or Imprisonment, to which the Court referred in Tibi v Ecuador. This principle establishes that “[a] proper medical examination shall be offered to a detained or imprisoned person as promptly as possible after his admission to the place of detention or imprisonment, and thereafter medical care and treatment shall be provided whenever necessary. This care and treatment shall be provided free of charge.” 523 Montero-Aranguren and Others v Venezuela (2006), op. cit., §102. The Court made reference to the findings of the European Court in Mathew v the Netherlands (2005), op. cit., in this respect. 524 Montero-Aranguren and Others v Venezuela (2006), op. cit., §85. 525 Berenson-Mejía v Peru (2004), op. cit., §101; Baena-Ricardo v Panama, IACHR (Series C) No. 72, judgement of 2 February 2001, §106. 526 Juvenile Reeducation Institute v Paraguay (2004), op. cit., §164. 521 116