Access to Outdoor Spaces and Recreational Activities
Access to outdoor spaces and recreational activities are considered a crucial element contributing to the
wellbeing of detainees by the Court, and a lack of possibility of activity in the open air can cause
applicants to "feel isolated from the outside world, with potentially negative consequences for his
physical and moral wellbeing".[236] The CPT is often referred to by the ECtHR in defining minimum
standards in this subject, which includes outdoor exercise and preferably, a broader programme of outof-cell activities.[237] Importantly, the outdoor space, or recreational area, should be "reasonably
spacious and whenever possible offer shelter from inclement weather", and while a minimum of one
hour per day outdoors is considered mandatory, “according to the relevant international standards
prisoners should be able to spend a reasonable part of the day outside their cells, engaged in purposeful
activity of a varied nature (work, recreation, education).”[238] The Court also judged that even in
absence of the intention to humiliate a detainee by placing them in poor conditions which do not
provide these minimum standards, a violation of Article 3 of the Convention could still be found.[239]
Thus, in 2013, the ECtHR states “quite apart from the necessity of having sufficient personal space,
other aspects of physical conditions of detention are relevant for the assessment of compliance with
Article 3. Such elements include, in particular, access to outdoor exercise, natural light or air, availability
of ventilation, adequacy of heating arrangements, (...)”.[240] Finally, the RCD specifies that detained
applicants - and those third country nationals detained in the same space according to Article 10(1) should have access to open-air spaces.[241]
In practice, people detained across Greece are provided with access to outdoor spaces, yet in limited
hours and spaces, depending on the PRDC. For example, access to outdoor courtyard space in Xanthi is
less restricted, but in Corinth detainees are only allowed outside for a few hours, and in Paranesti there
are only a few metres of space reducing the possibility for exercise. Respondents in Corinth described
the suffocating feeling of being kept in cells of 12 people without having access to the outdoors,
creating tensions and critical mental health. According to respondents, none of the PRDCs in mainland
Greece provided recreational activities or materials to do so, including both sports and educational
services. Several people we spoke to asked for us to send simple items such as footballs, to distract
them from their environments and support their mental wellbeing. Finally, our research found that
places of worship were not provided in detention facilities.
There is nothing, no gym, no football, no study or something.
There is nothing from this kind of activities.
Iliyes, Corinth
When they let us outside, it's a small place, we had only 2-3 metres in front of us; like
it’s close everywhere and we can not do sport, we can not do something or do any
activities, we didn't even have a ball, at least to play between ourselves or
something.
Sofiane, Paranesti
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