Chapter 8 • International Legal Standards for the Protection of Persons Deprived of Their Liberty they shall only be occupied by prisoners “suitable to associate with one another in those conditions” (Rule 9(2)). All prison accommodation of persons deprived of their liberty, including in particular the sleeping accommodation, “shall meet all requirements of health, due regard being paid to climatic conditions and particularly to cubic content of air, minimum floor space, lighting, heating and ventilation” (Rule 10). In all living and working places within places of detention, “the windows shall be large enough to enable the prisoners to read or work by natural light, and shall ... allow the entrance of fresh air whether or not there is artificial ventilation” (Rule 11(a)). “Artificial light shall be provided sufficient for the prisoners to read or work without injury to eyesight” (Rule 11(b)). Lastly, “the sanitary installations shall be adequate to enable every prisoner to comply with the needs of nature when necessary and in a clean and decent manner” (Rule 12; emphasis added). ***** The African Commission on Human and Peoples’ Rights concluded that article 5 of the African Charter was violated in the Ouko case, where the complainant alleged that the detention facility had a 250-watt electric bulb that had been left on throughout his ten-month-long detention; during this time, he had also been denied bathroom facilities and been subjected both to physical and to mental torture. In the view of the Commission these conditions contravened the complainant’s right to respect for his dignity and freedom from inhuman and degrading treatment as guaranteed by article 5 of the Charter.78 In addition to the specific conditions of Vera and Orton Chirwa, which were considered under subsection 2.3.2 above, the African Commission has also examined general prison conditions in Malawi. It concluded that the following conditions “offend the dignity of the person and violate” article 5 of the African Charter: “the shackling of hands in the cell so that the prisoner is unable to move (sometimes during the night and day), serving of rotten food, solitary confinement or overcrowding such that cells for 70 people are occupied by up to 200”. 79 ***** In the Greek case, the European Commission of Human Rights concluded that accommodation in the Lakki camp violated article 3 of the European Convention on Human Rights because of “the conditions of gross overcrowding and its consequences”; the dormitories could hold 100 to 150 persons.80 4.2.1 Separation of categories 78 ACHPR, John D. Ouko v. Kenya, Communication No. 232/99, decision adopted during the 28th Ordinary session, 23 October – 6 November 2000, paras. 22-33 of the text of the decision as published at http://www1.umn.edu/humanrts/africa/comcases/232-99.html. 79 ACHPR, Krishna Achuthan and Amnesty International (on behalf of Aleke Banda and Orton and Vera Chirwa) v. Malawi, Communications Nos. 64/92, 68/92 and 78/92, decision adopted during the 16th session, October-November 1994, para. 34 of the text of the decision as published at http://www.up.ac.za/chr/. 80 Eur. Comm. HR, Applications Nos. 3321-3323/67 and 3344/67, Denmark, Norway, Sweden and the Netherlands v. Greece, Report of the Commission adopted on 5 November 1969, 12 Yearbook 1969, p. 497, para. 21 and p. 494, para. 14. 340 Human Rights in the Administration of Justice: A Manual on Human Rights for Judges, Prosecutors and Lawyers