The European Court of Human Rights has recognised that the Article 3 prohibition1 may be violated by extended solitary confinement2. Complete sensory isolation, coupled with total social isolation can destroy the personality and constitutes a form of inhuman treatment which cannot be justified by the requirements of security or any other reason, although a lesser form of isolation, for example simple prohibition of contact with other prisoners for security, disciplinary or protective reasons, will not in itself amount to Article 3 treatment: a balance must be struck between the need for isolation and the effect that such isolation will
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