43 manner and method of any deprivation of liberty do not exceed the unavoidable level of suffering inherent in detention and that the detainee is not subjected to sufferings or hardships exceeding the unavoidable suffering inherent in detention, and that, given the practical requirements of encarceration, the detainee´s health and welfare are adequately warranted. 87. Besides, the State is in a special position of guarantor as to the persons deprived of their liberty, since jail authorities exercise a strong control or supervision over the persons under custody. Thus, there exists a special interaction and subordination relationship between the detainee and the State, a relationship which is characterized by the special strength the State may use to regulate their rights and duties, and by the particular circumstances of any deprivation of liberty, where the detainee cannot satisfy his/her personal basic needs by himself, though said needs are essential for the basic development of a dignified life.144 88. The Court deems it convenient to point out some of the facts acknowledged by the State as a violation of the right of the victims in this case to humane treatment, during their detention at the Detention Center of Catia. Said events are related to overcrowding, health services and hygiene and medical assistance to inmates. i) Overcrowding 89. Pursuant to the proven facts (supra para. 60(7) to 60(15)), persons detained in the Detention Center of Catia lived in conditions of severe prison overcrowding and overpopulation. The exact number of inmates at the time of the events of the instant case is not known with certainty due, inter alia, to the lack of an adequate record of the basic data of inmates. However, according to some estimates, the population of Catia Detention facilities ranged between 2286 to 3618 inmates, although its maximum capacity was 900 inmates. That is to say, the overpopulation was between 254 and 402 percent over its capacity. The available space for each inmate was about 30 square centimeters. Some cells used to house inmates during the night were designed for two persons, however, not less than six persons were held inside them. 90. The Court takes into account that, according to the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (hereinafter, the “CPT”), an overcrowded prison is characterized by non-hygienic and restricted living conditions, where privacy is absent even for the most basic activities such as the use of sanitary facilities; by the few out-of-the-cell activities due to the number of inmates that exceeded the available services; overburdened health services; increase of the climate of tension and therefore, increase of violence between prisoners and prison staff. This enumeration is not limited. Furthermore, the CPT provided that 7 square meters available for each prisoner is an approximate guideline and convenient space for a prison cell.145 On the other hand, the European Court of Human Rights held that a space of about 2 square meters available for an inmate involves a level of overcrowding that is per se questionable in the light of 144 Cf. Case of García Asto and Ramírez Rojas, Judgment of November 25, 2005. Series C No. 137, para. 221; Case of Raxcacó Reyes. Judgment of September 15, 2005. Series C No. 133, para. 95, and Case of Fermín Ramírez, Judgment of June 20, 2005. Series C No. 126, para. 118. 145 Cf. CPT/Inf (92) 3 [EN], 2nd General Report, 13 April 1992, para. 43.