of Prisoners”)328 in order to interpret the content of the right of those deprived of liberty to decent and humane treatment, as basic rules for their accommodation, hygiene, medical treatment and physical exercise, among other matters.329 These rules stipulate that “instruments of restraint shall never be applied as a punishment” and “shall not be used except in the following circumstances: (a) As a precaution against escape during a transfer, provided that they shall be removed when the prisoner appears before a judicial or administrative authority; (b) On medical grounds by direction of the medical officer; (c) By order of the director, if other methods of control fail, in order to prevent a prisoner from injuring himself or others or from damaging property; in such instances the director shall at once consult the medical officer and report to the higher administrative authority.330 199. Moreover, the United Nations Rules for the Treatment of Women Prisoners and Noncustodial Measures for Women Offenders (the Bangkok Rules) establish that “[i]nstruments of restraint shall never be used on women during labour, during birth and immediately after birth.”331 Several United Nations Special Rapporteurs have ruled similarly. 332 In addition, the European Court has indicated that the use of handcuffs on “an ill or otherwise weak person is disproportionate […] and implies an unjustifiable humiliation,” and if these are used for “a woman suffering labour pains and immediately after the delivery, it amounted to inhuman and degrading treatment.”333 200. When Manuela was detained, she had recently given birth and was being treated for severe preeclampsia. Therefore, it was unreasonable to assume that there was a real risk of United Nations Standard Minimum Rules for the Treatment of Prisoners, adopted by the First United Nations Congress on the Prevention of Crime and the Treatment of Offenders, held at Geneva in 1955, and approved by the Economic and Social Council by its resolutions 663 C (XXIV) of 31 July 1957 and 2076 (LXII) of May 13, 1977. 328 Cf. Case of Raxcacó Reyes v. Guatemala. Merits, reparations and costs. Judgment of September 15, 2005. Series C No. 133, para. 99, and Case of Hernández v. Argentina, supra, para. 87. 329 United Nations Standard Minimum Rules for the Treatment of Prisoners, adopted by the First United Nations Congress on the Prevention of Crime and the Treatment of Offenders, held at Geneva in 1955, and approved by the Economic and Social Council by its resolutions 663 C (XXIV) of 31 July 1957 and 2076 (LXII) of May 13, 1977, para. 33. In 2015, the United Nations General Assembly adopted the revised United Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules). They also stipulate that “Other instruments of restraint shall only be used when authorized by law and in the following circumstances: (a) As a precaution against escape during a transfer, provided that they are removed when the prisoner appears before a judicial or administrative authority; (b) By order of the prison director, if other methods of control fail, in order to prevent a prisoner from injuring himself or herself or others or from damaging property; in such instances, the director shall immediately alert the physician or other qualified health-care professionals and report to the higher administrative authority.” Cf. UN. United Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules). General Assembly Resolution A/RES/70/175, of December 17, 2015, rule 47(2) 330 United Nations Rules for the Treatment of Women Prisoners and Non-custodial Measures for Women Offenders (the Bangkok Rules), General Assembly Resolution A/RES/65/229 of March 16, 2011, rule 24. Similarly, see, United Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules). General Assembly Resolution A/RES/70/175, of December 17, 2015, rule 48(2) 331 The Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment has indicated that “[t]he use of shackles and handcuffs on pregnant women during labour and immediately after childbirth is absolutely prohibited and representative of the failure of the prison system to adapt protocols to unique situations faced by women.” In addition, in her report on a human rights-based approach to mistreatment and violence against women in reproductive health services with a focus on childbirth and obstetric violence, the Special Rapporteur on violence against women, it causes and consequences indicated that such measures may amount to violence against women and other human rights violations. Cf. Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, A/HRC/31/57 of January 5, 2016, para. 21, and Report of the Special Rapporteur on violence against women, its causes and consequences on a human rights-based approach to mistreatment and violence against women in reproductive health services with a focus on childbirth and obstetric violence, A/74/137 of July 11, 2019, para. 22. 332 Cf. ECHR [Fifth section]. Case of Korneykova and Korneykov v. Ukraine, No. 56660/12 of March 24, 2016, paras. 111 and 115. 333 58