For detention, specifically, to be considered under Article 3 ECHR, the suffering and humiliation involved must go beyond the inevitable element of suffering and humiliation connected with deprivation of liberty itself. That said, authorities must ensure that: (1) a person is detained in conditions compatible with respect for human dignity; (2) the manner and method of execution of a custodial sentence or other type of detention measure do not subject the person concerned to distress or hardship of an intensity exceeding the unavoidable level of suffering inherent in detention, and (3) that, given the practical demands of imprisonment, this person’s health and well-being are adequately secured.217 When assessing detention conditions under Article 3 ECHR, it is particularly important to account for the cumulative effects of these conditions, the specific allegations made by the person concerned, and the amount of time that he or she has spent in these conditions.218 Even where each individual aspect of these conditions complies with domestic law, their cumulative effect may be such as to result in inhuman or degrading treatment within the meaning of Article 3 ECHR.219 In general in these cases, the ECtHR considers the lack of personal space (overcrowding)220, access to outdoor exercise221, natural light and fresh air (availability of ventilation)222, adequacy of heating arrangements, the possibility of using the toilet in private, and compliance with basic sanitary and hygienic requirements.223 a. Increased Obligations of the State for persons wholly dependent on the State States have an obligation to respect, protect, and fulfil human rights. States’ obligation to protect and fulfil increases when the state has made persons largely dependent on the state through measures that restrict or deprive freedom in the context of detention or camp accommodation.224 When persons are totally dependent on the state because they cannot independently access shelter, medical care or sanitation and cannot protect themselves from violence, the ECHR imposes additional positive obligations on the state.225 b. Use of police detention Regarding detention location, the ECtHR has consistently held that prolonged detention in police stations, per se, violates Article 3 ECHR because of the conditions inherent to police stations.226 c. Inadequate food and water The Court has held that providing clearly insufficient food to a prisoner raises an issue under Article 3 of the Convention.227 In that regard, the Court has found a violation of Article 3 ECHR when detainees are only 217 Ibid. at 141, with further references. 218 Ibid. at 142, with further references. 219 ECtHR, Judgement of 27/01/2015, Nos 36925/10 et. al., Neshkov and Others v. Bulgaria, para 225 et. seq, ECtHR, Judgement of 10/12/2020, No. 42732/12, Ananyev and Others v. Russia, para 139-158. 220 ECtHR, Judgement of 23/07/2013, No. 55352/12, Aden Ahmed v. Malta, para 87, ECtHR, Judgement of 07/07/2005, No. 53254/99, Karaleviˇcius v. Lithuania, para 36; ECtHR, Judgement of 10/12/2020, No. 42732/12, Ananyev and Others v. Russia, para 143–148. 221 ECtHR, Judgement of 10/12/2020, No. 42732/12, Ananyev and Others v. Russia, para 150–152. 222 Ibid., paras 153–155. 223 ECtHR, Judgement of 23/07/2013, No. 55352/12, Aden Ahmed v. Malta, para 88. ECtHR, Judgement of 10/12/2020, No. 42732/12, Ananyev and Others v. Russia, para 156–159. 224 See also Council of Europe/European Court of Human Rights, Thematic Report: Health-related issues in the case law of the European Court of Human Rights, June 2015, p 13. 225 ECtHR, Judgment of 25/01/2011 - No. 38427/05 - Elefteriadis, para. 47. 226 ECtHR, Judgement of 04/10/2013, No. 50520/09, Ahmade v. Greece, para 101; ECtHR, Judgement of 28/02/2019, No. 19951/16, S.Z. v. Greece, para 40, ECtHR, Judgement of 21/06/2018, No. 66702/13, H.A. and others v. Greece, para 170, ECtHR, Judgement of 13/06/2019, No. 14165/16, Sh.D. and Others v. Greece, Austria, Croatia, Hungary, North Macedonia, Serbia and Slovenia. 227 ECtHR, Judgement of 07/11/2017, No. 37717/05 Dudchenko v. Russia, para 130. 37 DETENTION OF MIGRANTS ON THE ISLAND OF KOS