In at least one case, unaccompanied children not provided with care after release from detention have fallen into the hands of criminal gangs. Noorzai A., 18 years old at the time, told us how he, jointly with his eight-year-old brother and three other boys were abducted by a criminal gang after release from detention in Volos in late 2006. The gang locked the boys up, severely ill-treated them and blackmailed their relatives to pay ransom (their case is also discussed in chapter II).238 Legal Standards The Council of Europe’s Parliamentary Assembly has criticized the practice of detaining children and recommends they be placed in adequate care and reception structures instead.239 The European Convention on Human Rights (ECHR), the Convention on the Rights of the Child, and the International Covenant on Civil and Political Rights protect children from inhuman or degrading treatment.240 The European Court of Human Rights, in applying Article 3 of the ECHR which sets out the prohibition on such treatment, held that this protection entails a positive obligation on states to provide children with adequate protection against such treatment. In the case of Z and Others v. the United Kingdom, the court ruled against the UK government’s social service system because it failed to protect children from serious, long-term neglect and abuse.241 The European Commission of Human Rights, when it considered the admissibility of this case, specified that the protection of children who “by reason of their age and vulnerability are not capable of protecting themselves,” may imply a positive obligation on authorities to take preventive measures to protect a child who is at risk from another individual.242 Greece fails to take the minimum precautions to protect unaccompanied children as required by article 3 of the ECHR. There are insufficient care placements available, 238 Human Rights Watch interview with Noorzai A., June 2008 (exact date and place withheld). See also chapter II for more information about their case. 239 Council of Europe Parliamentary Assembly, “Protection and assistance for separated children seeking asylum,” Recommendation 1703 (2005), para. 5. 240 European Convention on Human Rights, art. 3, CRC, art. 37 (a), ICCPR, art. 7. 241 European Court of Human Rights, Z and Others v. the United Kingdom, (Application no. 29392/95), Judgment of 10 May 2001, available at www.echr.coe.int. 242 European Commission of Human Rights, Z and Others v. the United Kingdom, (Application no. 29392/95), Report of the Commission, adopted September 10, 1999, available at www.echr.coe.int, para. 93. 73 Human Rights Watch December 2008