• Lack of recreational activities. There is limited or no access to outdoor time or indoor leisure such as a television. • Inadequate facilities and infrastructure. There is a lack of sanitary facilities, ventilation, heating and cleaning services. Conditions for people in detention have long been criticized by civil society organizations. Moreover, detention conditions have been ruled incompatible with the European Convention on Human Rights (ECHR) by the European Court of Human Rights, and criticized by international organizations such as the United Nations Refugee Agency (UNHCR) and the Council of Europe’s Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT). Specifically, UNHCR noted in 2019 that ‘conditions and procedural safeguards continue to be problematic. […] Some of the main deficiencies of concern to UNHCR include […] seriously substantial substandard conditions of detention in the pre-removal centers, in particular in P. Ralli [Petrou Ralli] in Athens and Fylakio at Evros.’ 52 These major problems were also pointed out by the Greek Ombudsman in June 2021. 53 In 2020, the CPT called upon the Greek authorities to ‘… change the current approach towards immigration detention [and] to take decisive steps … to reform their immigration detention system [in line with] European values and norms’. 54 Although things seem to have improved since 2011, when the CPT – for the first and only time with regards to an EU Member State – issued a public statement concerning the detention conditions of migrants, the strong criticism remains. Its 2020 report notes that ‘regrettably, despite repeated recommendations by the Committee, the approach of Greek authorities has not evolved substantially’. 55 IN DENIAL: LACK OF RECOGNITION BY GREECE ON INHUMANE CONDITIONS IN DETENTION Finally, it is important to examine how the Greek justice system has addressed (or failed to address) the issue of detention conditions in the context of examination of remedies against detention. Poor detention conditions have often been invoked by appeal lawyers during detention reviews, as the court must decide not only on the necessity of detention, but also on the compatibility of detention with certain human rights conditions. The Greek administrative courts have been very reluctant to accept arguments based on the low standards of detention centres. In most cases, these arguments have been rejected as ‘vague and inadmissible’, with justification of detention centres on the basis that ‘direct medical care can be provided […] there is an area available for physical activity and by its nature it is not only intended for short stay’. In other cases, the conditions of detention are not examined at all. 56 18