Chapter 5 • Human Rights and Arrest, Pre-Trial and Administrative Detention in particular, article 9(4), which provides important judicial guarantees, are also applicable to cases of administrative deprivation of liberty.58 ***** Article 5(1)(d)-(f) of the European Convention authorizes categories of detention which are largely identical to those enumerated by the Human Rights Committee. However, it should be emphasized that they may not necessarily be imposed by administrative authorities, but may instead fall within the competence of the ordinary courts of law. Article 5(4) of the European Convention also provides important judicial guarantees with regard to all deprivations of liberty. The same holds true with regard to article 7(6) of the American Convention on Human Rights. These guarantees will be dealt with in further depth below. 4.7.1 Deprivation of liberty for the purpose of educational supervision In the case of Bouamar submitted under the European Convention on Human Rights, the applicant complained of having been subjected to nine periods of detention for up to fifteen days in a remand prison for the purpose of his “educational supervision”. The orders in question were based on the Belgian Children’s and Young Persons’ Welfare Act of 1965. The Court noted that “the confinement of a juvenile in a remand prison does not necessarily contravene sub-paragraph (d), even if it is not in itself such as to provide for the person’s ‘educational supervision’”. However, in such circumstances “the imprisonment must be speedily followed by actual application” of a regime of supervised education “in a setting (open or closed) designed and with sufficient resources for the purpose”.59 It did not share the Government’s view that the placements complained of were part of an educative programme, emphasizing that Belgium “was under an obligation to put in place appropriate institutional facilities which met the demands of security and the educational objectives of the 1965 Act, in order to be able to satisfy the requirements of” article 5(1)(d).60 “The detention of a young man in a remand prison in conditions of virtual isolation and without the assistance of staff with educational training” could not “be regarded as furthering any educational aim”; consequently, the placement orders – whereby the applicant had been deprived of his liberty for 119 days during a period of 291 days – were incompatible with article 5(1)(d) of the European Convention.61 58 Ibid., loc. cit. 59 Eur. Court HR, Bouamar Case, judgment of 29 February 1988, Series A, No. 129, p. 21, para. 50. 60 Ibid., pp. 21-22, para. 52. 61 Ibid., paras. 51-53. 176 Human Rights in the Administration of Justice: A Manual on Human Rights for Judges, Prosecutors and Lawyers