provided with one meal per day.228 A mere dissatisfaction with the quality of the food when provided three times a day and regularly inspected by the authorities does not constitute a violation of Article 3 ECHR.229 Article 9 ECHR obliges authorities to account for detainees’ religious beliefs when providing nutrition.230 While the Court accepts that special dietary requirements pose an additional financial and organizational burden on administrative authorities, it requires states to strike a fair balance between such considerations and the detained person’s freedom of belief. In that regard the Court has found the request for a religiously motivated vegetarian diet (Buddhism) reasonable and protected under Article 9 ECHR while a kosher diet was not found to be reasonable.231 When the need for a special diet is based on medical reasons, the Court does not accept any possible justification on economic grounds.232 Since detained persons are unable to seek medical help at any time from a hospital of their choosing, authorities are obliged under Article 3 ECHR to offer an adequate diet and protect the detained person’s well-being. d. Recreational Activities Regarding recreational activities in detention, the Court refers to European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) standards233 which include outdoor exercise, preferably as a broader programme of out-of-cell activities. Outdoor exercise facilities should be reasonably spacious and, whenever possible, offer shelter from inclement weather.234 The recreation area must be usable “in a meaningful way”.235 In that sense, the Court found a violation of Article 3 ECHR where an outdoor area was not usable due to bad weather conditions and not having a roof.236 e. Hygiene The Court has held that access to properly equipped and hygienic sanitary facilities is of paramount importance for maintaining prisoners’ sense of personal dignity. Not only are hygiene and cleanliness integral parts of the respect that individuals owe to their bodies and to their neighbours with whom they share premises for long periods of time, they also constitute a necessary condition for the conservation of health. A truly humane environment is not possible without ready access to toilet facilities or the possibility of keeping one’s body clean.237 228 ECtHR, Judgment of 04/05/2006, No. 62393/00, Kadikis v. Latvia (no. 2), para 55, ECtHR, Judgement of 06/11/2007, No. 8207/06, Stepuleac v. Moldova, para 55. 229 ECtHR, Judgement of 20/10/2016, No. 7334/13, Muršić v. Croatia [GC], 2016, para 166. 230 ECtHR, Judgement of 02/05/1997, No. 146/1996/767/964, D and E.S. v. United Kingdom, 1990, Commission decision, ECtHR, Judgement of 07/12/2010, No. 18429/06, Jakóbski v. Poland, para 45; ECtHR, Judgement of 17/12/2013, No. 14150/08, Vartic v. Romania, para 44-55. 231 ECtHR, Judgement of 07/12/2010, No. 18429/06, Jakóbski v. Poland, ECtHR, Judgement of 09/06/2020, Nos 23735/16 & 23740/16, Erlich and Kastro v. Romania, para 44. 232 ECtHR, Judgement of 13/03/2018, No. 10839/09, Ebedin Abi v. Turkey, para 31-54. 233 See for example European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT), Factsheet Immigration Detention (March 2017), CPT/Inf(2017)3, available at https://rm.coe.int/16806fbf12. 234 ECtHR, Judgement of 10/12/2020, No. 42732/12, Ananyev and Others v. Russia, para 125, 150, ECtHR, Judgement of 09/10/2008, No. 62936/00, Moiseyev v. Russia, para 125. 235 ECtHR, Judgement of 20/10/2011, Nos 5774/10 & 5985/10, ECtHR, Judgment of 20/10/2011, Nos 5774/10 & 5985/10, Mandić and Jović v. Slovenia, para 78. 236 Ibid at para 78. 237 ECtHR, Judgement of 10/12/2020, No. 42732/12, Ananyev and Others v. Russia, para 156. 38 DETENTION OF MIGRANTS ON THE ISLAND OF KOS