CEDH · CASELAW;DECISIONS;ADMISSIBILITYCOM;ENG — 19 novembre 2020

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The applicants’ complaints under Article 3 of the Convention concerning the inadequate conditions of detention were communicated to the Russian Government (“the Government”). In some of the applications, complaints under Article 13 of the Convention about absence of domestic remedies in Russia to complain about poor conditions of detention were also communicated to the Government. THE LAW Joinder of the applications Having regard to the similar subject matter of the applications, the Court finds it appropriate to examine them jointly in a single decision. Complaints under Article 3 of the Convention (inadequate conditions of detention) and under Article 13 of the Convention (lack of an effective remedy) The applicants complained of the conditions of their detention in violation of the national requirements during periods which had already come to an end (for further details see the appended table). Some applicants also argued that they did not have an effective domestic remedy to complain about those conditions at the national level. Articles 3 and 13   read as follows: Article 3 Prohibition of torture “No one shall be subjected to torture or to inhuman or degrading treatment or punishment.” Article 13 Right to an effective remedy “Everyone whose rights and freedoms as set forth in [the] Convention are violated shall have an effective remedy before a national authority notwithstanding that the violation has been committed by persons acting in an official capacity.” The Government submitted their observations, disputing the violations alleged. On 10 January 2020 the Government submitted additional information about the new Compensation Act and asked to treat it as a new remedy in respect of conditions of detention complaints under Articles 3   and 13 of the Convention. The applicants maintained their complaints. In its recent decision of Shmelev and Others v. Russia ((dec.), no.   41743/17 and 16 others, 17 March 2020), the Court has examined similar applications lodged by Russian applicants and declared them inadmissible for non-exhaustion of domestic remedies. In particular, the Court took into account that on 27   January 2020 the new Compensation Act entered into force in Russia. It noted that the Act provides that any detainee who alleges that his or her conditions of detention are in breach of national legislation or international agreements of the Russian Federation can apply to a court. The novelty of the Act is that a (former) detainee can claim, at the same time, a finding of a violation of inadequate detention conditions and financial compensation for such breach. “122. The Court reiterates that, where the detention is over, a compensatory remedy can suffice to provide the applicants with fair redress for the alleged breach of Article 3 (see case-law cited above in paragraph 87). Accordingly, it is sufficient to examine whether the applicants concerned can be required to exhaust the compensatory remedy. 123. As mentioned above, the Court may examine the effectiveness of a newly introduced domestic remedy even if it was not available at the time of lodging of applications, where such remedy is introduced at a later stage in response to the Court’s finding of a systemic problem (see paragraph 106 above and the case-law cited therein). 124. The Court has concluded that the Compensation Act presents, in principle, an adequate and effective avenue for compensatory redress in cases raising issues of improper conditions of pre-trial detention. It has found that it is directly accessible to the persons concerned, is furnished with the requisite procedural guarantees associated with judicial adversarial proceedings, that there are no reasons to expect that such claims would not be processed within a reasonable time, or that the compensation would not be paid promptly. It also concluded that the system offers reasonable prospects of success to the applicants in terms of the compensation awards. 125. The Compensation Act is equipped with transitional provisions, so that any person whose complaint about inadequate conditions of detention was pending with this Court at the time of the Act’s entry into force can apply within 180 days after that date (see paragraph 63 above). The same would apply to those whose complaints would be declared inadmissible by this Court in view of the Act coming into force. 126. The Court accepts that the domestic courts have not yet been able to establish any practice under the Compensation Act. However, the Court has already found that doubts about the prospects of a remedy, which appears to offer a reasonable possibility of redress, are not a sufficient reason to eschew it (see Shtolts and Others , cited above, § 111). 127. Accordingly, even though the domestic remedy was not available to the applicants at the time when they applied to the Court, the situation justifies a departure from the general rule on exhaustion and requires the applicants in question to seek compensation under the Compensation Act. 128. The Court accepts that the outcome of the applicants’ claims under the new provisions cannot at present be ascertained. However, as the Court has already noted on similar occasions, it would remain open for the applicants to lodge fresh complaints should their claims to the domestic courts prove unsuccessful, for one reason or another. The Court’s ultimate supervisory jurisdiction remains in respect of any complaints lodged by the applicants who, in conformity with the principle of subsidiarity, have exhausted available avenues of redress (see Domján , § 37; and Shtolts and Others , §§ 112-113, both decisions cited above). The Court will remain free to assess the compliance of application of the domestic practice with the pilot judgment and the Convention standards in general, summary of the relevant case-law in paragraph 82 above). 129. Finally, the Court does not lose sight of a number of positive developments related to the situation with pre-trial detention in Russia that will be analysed below.” Having thus considered that there exists an effective remedy in Russia for cases where applicants complain about a breach of Article 3 in respect of past pre-trial detention, and having dismissed the applications by such applicants for non-exhaustion, the Court declared that it will apply that approach to all similar applications (see Shmelev and Others (dec.)., cited above, § 130). The Court also found that applicants who complained about their detention in overcrowded conditions of post-conviction facilities in violation of the national statutory norm of two square metres per person, and where their detention in such conditions was already over, found themselves in a situation similar to that of persons whose past pre-trial detention had been in breach of the applicable national standards. The Court stressed that for them, as well as for other persons in similar situation, the new Compensatory Act presents, in principle, an adequate and effective avenue of obtaining compensatory redress, and offers reasonable prospects of success (see Shmelev and Others (dec.)., cited above, § 154). It thus also rejected for non-exhaustion of domestic remedies applications where applicants complained about post-conviction detention in violation of the national statutory standard and decided that actual or potential applicants finding themselves in a similar situation – i.e. where the complaint concerns past correctional detention in conditions in breach of the applicable domestic standards – are also expected to first make use of the compensatory remedy introduced in January 2020 ( Shmelev and Others , (dec.)., cited above, §§ 155-156). Turning to the circumstances of the present cases and having examined all the material submitted to it, the Court has not found any fact or argument capable of persuading it to reach a different conclusion on the admissibility of these complaints. In particular, the Court observes that two applicants complained about the conditions of their detention in colony IK ‑ 56 in the Sverdlovsk Region. In addition to specific grievances listed in the table attached below, the applicants provided similar description of the general conditions. While not arguing that they lacked personal space as such, the applicants nevertheless complained about degrading treatment relating to the lack of water-supply and sewage systems in IK-56 colony, and the absence of proper sanitary installations in the cells. The treatment they complained of consisted of the necessity to relieve themselves in a bucket, often in the presence of another inmate, and to endure difficulties as a result of the lack of sanitary facilities, such as the unpleasant odour in the cells, poor hygiene and the daily obligation to empty and clean the bucket. Those conditions in IK-56 of the Sverdlovsk Region were already the subject of the Court’s criticism, when it held that the lack of access to proper sanitary facilities run counter to the guarantees of Article 3 of the Convention (see Gorbulya v. Russia , no. 31535/09, § 94, 6 March 2014). The Court in this respect does not lose sight of the parties’ submissions that the Russian authorities decided to close the facility and that by the summer 2018 all inmates were transferred from it. It is clear that the conditions in IK ‑ 56   colony ran counter to the domestic legal requirements. It thus follows that the applicants who complained about the conditions of their detention in IK-56 colony in Sverdlovsk Region were in the same position as applicants who complained about their detention in overcrowded conditions of post-conviction facilities in violation of the national statutory norm of two square metres per person (see Shmelev and Others (dec.)., cited above, § 154). To sum up, the Court considers that in so far as the applicants have lodged prima facie well-founded complaints about breach of their rights by improper conditions of their detention, as described in the appended table, the Compensation Act afforded them an opportunity to obtain compensatory redress. Accordingly, the applicants should exhaust this remedy before their complaints can be examined by the Court. It follows that their complaints, as listed in the appended table, under Articles 3 and 13 should be declared inadmissible pursuant to Article 35 §§ 1 and 4 of the Convention. For these reasons, the Court, unanimously, Decides to join the applications; Declares the applications inadmissible. Done in English and notified in writing on 10 December 2020.   Liv Tigerstedt   Darian Pavli   Acting Deputy Registrar   President APPENDIX List of applications raising complaints under Article   3 of the Convention (inadequate conditions of detention) No. Application no. Date of introduction Applicant’s name Year of birth   Representative’s name and location Facility Start and end date Duration Inmates per brigade Sq. m per inmate Number of toilets per brigade Specific grievances     17901/17 21/02/2017 Igor Nikolayevich LEBEDEV 1982     IK-1 Nizhniy Novgorod Region 04/08/2014 to 13/06/2019 4 year(s) and 10 month(s) and 10 day(s) 130 inmate(s) < 2 m² 6 toilet(s) Lack or insufficient quantity of food, no or restricted access to warm water, lack of or restricted access to leisure or educational activities, lack of or poor quality of bedding and bed linen.     19520/17 22/05/2017 Erik Eduardovich KUCHIYEV 1979     IK-11 Nizhniy Novgorod Region 01/12/2014 to 08/06/2020 5 year(s) and 6 month(s) and 8 day(s) 58 inmate(s) 1.5 m² 6 toilet(s) Lack of fresh air, lack of or insufficient physical exercise in fresh air, lack of or inadequate hygienic facilities, no or restricted access to toilet, overcrowding, passive smoking, poor quality of food, lack of or insufficient natural light.     20412/17 03/03/2017 Gennadiy Mingishevich KHABBASOV 1973 Yesina Tatyana Robertovna Sevastopol IK-56 Sverdlovsk Region 26/06/2012 to 11/11/2017 5 year(s) and 4 month(s) and 17 day(s)   No or restricted access to toilet, lack of privacy for toilet, lack of or inadequate hygienic facilities, no or restricted access to running water, lack of or insufficient natural light, lack of fresh air, inadequate temperature, lack of or insufficient physical exercise in fresh air, no or restricted access to shower, carrying out of toilet cistern by handcuffed prisoners.     20720/17 27/02/2017 Ayub Vakhayevich EDISHEV 1982     IK-11 Nizhniy Novgorod Region 31/01/2013 to 04/10/2017 4 year(s) and 8 month(s) and 5 day(s) 1.7 m² Overcrowding, no or restricted access to running water, no or restricted access to toilet, lack of or inadequate hygienic facilities, lack or inadequate furniture, poor quality of food, no or restricted access to shower, lack of fresh air, mouldy or dirty cell.     49037/17 31/05/2017 Anatoliy Anatolyevich YAROSHA 1979     IK-5 Krasnoyarsk Region 12/04/2016 to 20/07/2017 1 year(s) and 3 month(s) and 9 day(s) 100 inmate(s) 1.9 m² 6 toilet(s) Lack of fresh air, lack of or insufficient physical exercise in fresh air, lack of privacy for toilet, no or restricted access to toilet.     53742/17 29/06/2017 Maksim Stanislavovich STAVSKIY 1974     IK-7 St Petersburg and IZ-47/1 St Petersburg 01/12/2015 to 17/08/2017 1 year(s) and 30 day(s) 100 inmate(s) < 2 m² 3 toilet(s) Lack of privacy for toilet, no or restricted access to running water, lack of fresh air, no or restricted access to shower.     56736/17 20/03/2017 Maciej KILJAŃSKI 1970     LIU-4 Karelia Republic 09/12/2015 to 21/09/2016 9 month(s) and 13 day(s) 4 toilet(s) <2 m²   Inadequate temperature, infestation of cell with insects/rodents, lack of fresh air, lack of or inadequate hygienic facilities, lack of or insufficient electric light, lack of privacy for toilet, no or restricted access to warm water, no or restricted access to shower, no or restricted access to potable water, overcrowding, poor quality of food.     57935/17 07/09/2017 Sholban Romanovich MONGUSH 1978     IK-2 Zabaykalskiy Region 22/02/2014 to 16/09/2020 6 year(s) and 6 month(s) and 26 day(s) <2 m² Infestation of cell with insects/rodents, lack of or inadequate hygienic facilities, lack of or insufficient natural light, lack of privacy for toilet, lack or inadequate furniture, lack or insufficient quantity of food, no or restricted access to warm water, no or restricted access to shower, no or restricted access to running water, poor quality of food.     60189/17 26/07/2017 Agil Dzhalil-ogly KERIMOV 1967     IK-5 Krasnoyarsk Region 13/08/2012 to 14/03/2018 5 year(s) and 7 month(s) and 2 day(s) 26 inmate(s) 0.5 m² Inadequate temperature, lack of fresh air, lack of or inadequate hygienic facilities, lack of or insufficient physical exercise in fresh air, lack of or restricted access to leisure or educational activities, lack of privacy for toilet, no or restricted access to running water, no or restricted access to shower, no or restricted access to toilet, poor quality of food.   69046/17 16/08/2017 Igor Valeryevich VINOGRADOV 1983     IK-5 Kirov Region 02/10/2015 to 22/02/2017 1 year(s) and 4 month(s) and 21 day(s) 1.6 m² Overcrowding, lack or inadequate furniture, lack of or inadequate hygienic facilities, inadequate temperature, no or restricted access to warm water, mouldy or dirty cell, poor quality of food.   69097/17 04/08/2017 Rodion Valeryevich YARUSENKO 1979     IK-5 Krasnoyarsk Region 11/11/2014 to 10/09/2020 5 year(s) and 10 month(s) 104 inmate(s) 1.85 m² 4 toilet(s) Lack of or insufficient electric light, overcrowding, lack of privacy for toilet, lack of or inadequate hygienic facilities, lack of fresh air.   69434/17 11/09/2017 Valeriy Nikolayevich SMIRNOV 1986     IK-11 Nizhniy Novgorod Region 27/02/2012 to 22/08/2017 5 year(s) and 5 month(s) and 27 day(s) 1.6 m² Insufficient number of sleeping places, lack of fresh air, lack or inadequate furniture, no or restricted access to toilet, no or restricted access to running water, infestation of cell with insects/rodents, lack of or insufficient physical exercise in fresh air, passive smoking.   69763/17 08/09/2017 Timur Vladimirovich TITOV 1988     IK-11 Nizhniy Novgorod Region 05/12/2011 to 13/03/2018 6 year(s) and 3 month(s) and 9 day(s) <2 m² Lack of or inadequate hygienic facilities, lack of or insufficient physical exercise in fresh air, lack of or poor quality of bedding and bed linen, lack or insufficient quantity of food, no or restricted access to shower, sharing cells with inmates infected with contagious disease, poor quality of food, passive smoking, overcrowding, no or restricted access to toilet.     69777/17 19/07/2017 Firuz Khidirovich AYTUGANOV 1989     IK-56 Sverdlovsk Region 13/03/2013 to 05/01/2018 4 year(s) and 9 month(s) and 24 day(s)   Lack of fresh air, lack of or inadequate hygienic facilities, lack of or insufficient physical exercise in fresh air, no or restricted access to potable water, no or restricted access to shower, no or restricted access to warm water.   71545/17 30/08/2017 Aleksandr Leonidovich UVAROV 1975 Shirokov Oleg Valeryevich Nizhniy Tagil IVS Krasnoturyinsk, Sverdlovsk Region; PFRSI IK-349/54 Sverdlovsk Region; IZ-66/1 Yekaterinburg; IZ-66/3 Nizhny Tagil 24/07/2009 to 12/12/2014 5 year(s), 4 month(s) and 20 day (s)   IK-78/4 Ulyanovsk 13/12/2014 to 29/08/2016 1 year(s) and 8 month(s) and 17 day(s)     IK-78/9 Ulyanovsk (medical unit) 30/08/2016 to 01/03/2017 6 month(s) and 2 day(s) 2 m²             100 inmate(s) 1.8 m² 4 toilet(s)       80 inmate(s) 2 m² 3 toilet(s) Overcrowding, insufficient number of sleeping places, lack of fresh air, passive smoking, lack of or insufficient electric light, lack of or insufficient natural light, sharing cells with inmates infected with contagious disease;       Overcrowding, lack of fresh air, lack of or insufficient natural light, lack of or insufficient electric light, no or restricted access to toilet, lack of or insufficient physical exercise in fresh air;     Overcrowding, sharing cells with inmates infected with contagious disease, lack of fresh air, no or restricted access to running water, passive smoking, no or restricted access to toilet, lack of privacy for toilet, no or restricted access to shower, mouldy or dirty cell, poor quality of food.   71641/17 18/09/2017 Sergey Anatolyevich AYKIN 1974     IK-2 Tomsk Region 25/05/2009 to 16/06/2017 8 year(s) and 23 day(s) 120 inmate(s) 1 m² 4 toilet(s) Lack of or inadequate hygienic facilities, lack of or insufficient electric light, lack of or insufficient natural light, lack of fresh air, lack of or poor quality of bedding and bed linen, lack or insufficient quantity of food, mouldy or dirty cell, no or restricted access to potable water, no or restricted access to shower, no or restricted access to warm water, overcrowding, passive smoking, poor quality of food, poor quality of potable water.   78118/17 01/03/2018 Andrey Nikolayevich MOZHAYEV 1975     IK-3 Sverdlovsk Region 02/05/2013 to 19/01/2018 4 year(s) and 8 month(s) and 18 day(s) 50 inmate(s) 1.5 m² Overcrowding, poor quality of food, lack or insufficient quantity of food, infestation of cell with insects/rodents, lack of or insufficient natural light, lack of fresh air, lack of or inadequate hygienic facilities.   78398/17 29/10/2017 Sergey Ivanovich TATARINOV 1966     IK-9 Volgograd 14/01/2016 to 22/12/2017 1 year(s) and 11 month(s) and 9 day(s) 100 inmate(s) 1.2 m² Lack of or insufficient electric light, no ventilation, inadequate temperature, passive smoking, no or restricted access to shower, no or restricted access to warm water, lack of privacy for toilet, poor quality of food.     81701/17 14/11/2017 Ivan Yuryevich MITYASHENKOV 1986     IK-11 Nizhniy Novgorod Region 21/05/2012 to 03/09/2020 8 year(s) and 3 month(s) and 14 day(s) 40 inmate(s) 1.6 m² 6 toilet(s) Overcrowding, no or restricted access to toilet, no or restricted access to shower.   1520/18 19/12/2017 Vladimir Artashevich ZAKARYAN 1979     IK-11 Nizhniy Novgorod 27/05/2013 to 26/06/2018 5 year(s) and 1 month(s) < 2 m² Lack of fresh air, overcrowding, poor quality of food.   14081/18 05/03/2018 Dmitriy Aleksandrovich IVANOV 1983     IK-29 Kirov Region 26/06/2017 to 28/02/2018 8 month(s) and 3 day(s) 1.2 m² Overcrowding, poor quality of food, lack or insufficient quantity of food, lack of seasonal clothing and footwear, lack of or poor quality of bedding and bed linen, lack of fresh air, lack of or insufficient natural light, lack of privacy for toilet, bad odour in cells, poor sanitary conditions in cell, no or restricted access to running water, lack or inadequate furniture.     14108/18 13/03/2018 Aleksey Aleksandrovich YURCHENKO 1995 Makhlyagin Yuriy Petrovich Krasnoturyinsk IK-53 Sverdlovsk Region 13/09/2014 to 29/09/2017 3 year(s) and 17 day(s) 1 m² Overcrowding, inadequate temperature, lack of fresh air, shower once a week, lack of or inadequate hygienic facilities, lack of or insufficient physical exercise in fresh air.   14993/18 13/03/2018 Sergey Aleksandrovich KHUDOV 1977     IK-13 Sverdlovsk Region 19/12/2016 to 03/11/2017 10 month(s) and 16 day(s) 1 m² Overcrowding, inadequate temperature, poor quality of food.   21602/18 23/04/2018 Mikhail Aleksandrovich MAKAROV 1970     IK-11 Nizhniy Novgorod Region 01/08/2010 to 31/05/2018 7 year(s) and 10 month(s) 1.5 m² Lack of or restricted access to leisure or educational activities, inadequate temperature, lack of or inadequate hygienic facilities, infestation of cell with insects/rodents, lack of or insufficient physical exercise in fresh air, poor quality of food.   22220/18 15/04/2018 Igor Vladimirovich VYLEGZHANIN 1967     IK-11 Nizhniy Novgorod Region 01/08/2013 to 15/05/2020 6 year(s) and 9 month(s) and 15 day(s) 130 inmate(s) < 2 m² Overcrowding, lack or inadequate furniture, lack of or insufficient electric light, lack of fresh air, insufficient number of toilets and wash basins, infestation of cell with insects/ rodents, insufficient space of the exercise yard, poor quality of food.   28587/18 25/05/2018 Ramil Ravilyevich AYNETDINOV 1977     IK-11 Nizhniy Novgorod Region 30/06/2014 to 27/05/2019 4 year(s) and 10 month(s) and 28 day(s) 130 inmate(s) 1.4 m² 8 toilet(s) Poor quality of food, no or restricted access to shower, inadequate clothing.   29149/18 04/06/2018 Vitaliy Andreyevich SHUSTOV 1989     IK-11 Nizhniy Novgorod Region 08/02/2016 to 27/08/2019 3 year(s) and 6 month(s) and 20 day(s) 1.5 m² 6 toilet(s) Infestation of cell with insects/rodents, lack of fresh air, lack of or inadequate hygienic facilities, no or restricted access to shower, no or restricted access to toilet, overcrowding, poor quality of food, lack or insufficient quantity of food   30179/18 13/06/2018 Denis Sergeyevich DAVYDOV 1986     IK-11 Nizhniy Novgorod Region 27/04/2017 to 21/05/2019 2 year(s) and 25 day(s) < 2 m² 6 toilet(s) Lack of fresh air, lack of or inadequate hygienic facilities, lack of or insufficient physical exercise in fresh air, no or restricted access to shower, no or restricted access to running water, no or restricted access to warm water, overcrowding, poor quality of food.   30312/18 05/06/2018 Viktor Alekseyevich RINGST 1992     IK-1 Arkhangelsk Region 29/09/2011 to 24/09/2018 6 year(s) and 11 month(s) and 27 day(s) 81 inmate(s) 1.8 m² 4 toilet(s) Overcrowding, lack of or inadequate hygienic facilities, no or restricted access to warm water, poor quality of potable water, poor quality of food, lack or insufficient quantity of food, insufficient number of toilets and wash basins.   33538/18 25/06/2018 Askarali Akhmedovich ANNAYEV 1984     IK-11 Nizhniy Novgorod 24/06/2013 to 30/04/2019 5 year(s) and 10 month(s) and 7 day(s) 110 inmate(s) 1 m² Poor quality of food, sharing cells with inmates infected with contagious disease, lack of or inadequate hygienic facilities.   34507/18 27/08/2018 Viktor Viktorovich PANFILOV 1968     IK-2 Zabaykalskiy Region 10/12/2013 to 26/05/2020 6 year(s) and 5 month(s) and 17 day(s) 1.8 m² Lack of or insufficient natural light, lack of fresh air, infestation of cell with insects/rodents, lack of privacy for toilet, no or restricted access to warm water, no or restricted access to shower, poor quality of food, lack of or restricted access to leisure or educational activities, no or restricted access to running water, no or restricted access to toilet.   41925/18 17/08/2018 Yevgeniy Vladimirovich KAZANTSEV 1987     IK-11 Nizhniy Novgorod Region 01/06/2017 to 14/08/2020 3 year(s) and 2 month(s) and 14 day(s) 10 inmate(s) 1.8 m² Lack of fresh air, poor quality of food, overcrowding, infestation of cell with insects/rodents.   44276/18 01/11/2018 Andrey Nikolayevich OSOKIN 1984     IK-2 Zabaykalskiy Region 08/01/2018 01/09/2020 2 year(s) and 7 month(s) and 25 day(s) 1.6 m² Lack of fresh air, lack of or insufficient natural light, inadequate temperature, infestation of cell with insects/rodents, overcrowding.   47558/18 26/11/2018 Ivan Anatolyevich OLYUSHKEVICH 1988     IK-8 Komi Republic 01/08/2016 to 28/08/2020 4 year(s) and 28 day(s) 145 inmate(s) 1.6 m² 6 toilet(s) Overcrowding, poor quality of food, dirty cutlery, lack of fresh air, lack of or restricted access to leisure or educational activities, insufficient number of toilets and wash basins, no or restricted access to running water, no or restricted access to warm water, lack of or insufficient electric light, lack of or inadequate hygienic facilities, no or restricted access to shower, mouldy or dirty cell.   56293/18 15/11/2018 Aleksey Sergeyevich TAUKELOV 1979     IK-2 Zabaykalskiy Region 18/12/2016 to 09/09/2020 3 year(s) and 8 month(s) and 23 day(s) 1.6 m² Lack of or insufficient electric light, lack of or inadequate hygienic facilities, infestation of cell with insects/rodents, lack of fresh air, overcrowding.   18973/19 22/03/2019 Maksim Leonidovich PUPYSHEV 1979     IK-1 Komi Republic 19/02/2015 to 07/07/2020 5 year(s) and 4 month(s) and 19 day(s) 1.5 m² Overcrowding, insufficient number of sleeping places, lack of fresh air, no or restricted access to running water, no or restricted access to toilet, poor quality of food.