3 Administrative detention in Greece: Findings from the field (2018) country and use of false travel documents. According to the Greek Ombudsman, such practices create “issues of misuse of power, undermining of the law and infringement of the principle of separation of powers”. 4. The imposition of the measure of detention against persons who belong to vulnerable groups, including families with minors and unaccompanied children, has not stop during 2018. Moreover, persons belonging to vulnerable groups were often detained in completely inappropriate conditions and were not provided with the appropriate medical care. The deprivation of freedom of vulnerable persons constitutes, by definition, an extremely burdensome and disproportionate measure, which does not comply with the guarantees prescribed by law. During the previous year, GCR handled cases of single-parent families, as well as cases of people, who, among others, were victims of tortured or had serious health, including mental health, problems. Due to the absence of sufficient places in accommodation facilities, unaccompanied children remain detained in completely inappropriate places for periods ranging from a few days to many months, depending on the circumstances, under the pretext of “protective custody”, which is a de facto detention measure. In some cases, unaccompanied children remain under protective custody for prolonged periods during which they reach adulthood. Subsequently, instead of being transferred to an accommodation facility, they remain detained in the context of removal procedures. This is for example the case of a minor, citizen of Pakistan, who reached adulthood during his five-month stay under protective custody in the Reception and Identification Centre (RIC) of Evros and he was transferred to the PRDC of Paranesti, where he was placed in detention in order to be returned. Moreover, unaccompanied minors in detention are deprived of any procedurals guarantess with regards the age assessment procedure due to the lack of a legislative framework regulating the age assessment procedure for persons under the responsibility of the police. This is for example the case of an unaccompanied minor, citizen of Bangladesh, who was wrongfully registered as an adult and was placed in detention, together with adults, in the Tavros PRDC. Due to the lack of an age assessment procedure, and despite the fact that he had in his possession the original birth certificate, he was subjected to medical examinations, which have a significant margin of error by their nature. On the basis of these examinations he was considered as an adult. Following an intervention by GCR, the authenticity of the original document was confirmed, he was registered as a minor and the procedure for finding the appropriate accommodation facility began. In November 2018, the European Council on Refugees and Exiles (ECRE) and the International Commission of Jurists (ICJ), with the support of the Greek Council for Refugees, lodged a Collective Complaint before the European Committee of Social Rights of the Council of Europe. The complainant organisations requested inter alia, the practice of detention / “protective custody” of unaccompanied minors to be considered as a violation of the right to accommodation and of the right of children and young people to protection, as enshrined in the Revised European Social Charter.