(3) Every prisoner shall be allowed to make a request or complaint, without censorship as to substance but in proper form, to the central prison administration, the judicial authority or other proper authorities through approved channels. (4) Unless it is evidently frivolous or groundless, every request or complaint shall be promptly dealt with and replied to without undue delay. The Guidelines and Measures for the Prohibition and Prevention of Torture, Cruel, Inhuman or Degrading Treatment or Punishment in Africa (The Robben Island Guidelines) require that States should: 17. Ensure the establishment of readily accessible and fully independent mechanisms to which all persons can bring their allegations of torture and ill-treatment. IMPLICATIONS It is of fundamental importance that all prison systems should be administered in a manner which is fair and just, and which is seen to be so. One way of ensuring this is that there should be a clearly defined set of procedures which allow a prisoner to make a request or complaint, or to air a grievance, without fear of reprisal. The prisoner must have some confidence that such a request, complaint or grievance will be considered fairly and objectively. The procedures for dealing with these issues must be drawn up in such a way that they can be understood and accepted both by prisoners and by those who are responsible for the administration of prisons. Any system of complaints and redress for grievances must be based on the principles of fairness and justice. It is in the interest of all concerned that the system for dealing with requests, complaints and grievances should include certain characteristics. These include accessibility, credibility, openness, reasonableness, objectivity, sensitivity, flexibility, efficiency and speed. There are at least five main possible areas for complaint by a prisoner: ■ Allegations of criminal behaviour: Sometimes prisoners will allege that either members of staff or other prisoners have engaged in activities that contravene criminal law. Although prison officials typically have powers to investigate and punish disciplinary offences by both staff and prisoners, they do not normally have any powers in the field of criminal investigation or prosecution. Nor do they have powers to decide whether there should be an investigation into or a prosecution of allegations of behaviour which is contrary to the criminal law. Any allegation of such behaviour should be referred immediately to the responsible authorities. ■ Claims for civil damages: There are a variety of circumstances in which prisoners may claim that officials have exercised inadequate care in managing prisons and that, as a consequence, they have a legitimate claim to civil damages. In some countries, claims have been lodged by prisoners in respect of health and safety regulations, hygiene legislation, health care and the protection of prisoners from assault by other prisoners known to be dangerous. Prisoners who wish to pursue such claims should be allowed free and confidential access to the courts. ■ Complaints of poor practice: Complaints which do not amount to claims for damages can arise from many areas of prison activity. Meals can be badly cooked or 131