44 Article 3 of the European Convention on Human Rights,146 and that it cannot be considered an acceptable standard,147 and that a cell of 7 square meters for two inmates was a relevant aspect to determine the existence of a violation of said Article.148 Similarly, the European Court held that a cell measuring 16.65 square meters where 10 detainees were held, involved a severe lack of space.149 91. In the instant case, the space of about 30 square centimeters available for each inmate is absolutely unacceptable and involves per se cruel, inhuman and degrading treatment, contrary to the dignity inherent to human being and, therefore, a violation to Article 5(2) of the American Convention. 92. Likewise, large-capacity dormitories inevitably imply a lack of privacy for prisoners in their everyday lives. Moreover, the risk of intimidation and violence is high. Such accommodation arrangements are prone to foster the development of offender subcultures and to facilitate the maintenance of the cohesion of criminal organisations. They can also render proper staff control extremely difficult, if not impossible; more specifically, in case of prison disturbances, outside interventions involving the use of considerable force are difficult to avoid. With such accommodation, the appropriate allocation of individual prisoners, based on a case by case risk and needs assessment, also becomes an almost impossible exercise.150 93. The Court considers that the solitary confinement cells where some inmates of the Detention Center of Catia were sent, were deplorable and extremely small. 94. The Court deems that solitary confinement cells must be used as disciplinary measures or for the protection of persons151 only during the time necessary and in strict compliance with the criteria of reasonability, necessity and legality. Such places must fulfill the minimum standards for proper accomodation, sufficient space and adequate ventilation, and they can only be used if a physician certifies that that the prisoner is fit to sustain it.152 The Court emphatically points out that confinement in a dark cell153 and incommunication154 are forbidden. To such end, the United Nations Committee against Torture has established that confinement cells measuring 60 x 80 146 Cf. ECHR, Case of Kalashnikov v. Russia. Judgment of 15 July 2002. Application No. 47095/99, para. 97. 147 Cf. ECHR, Case of Ostrovar v. Moldova. Judgment of 13 September 2005. Application No. 35207/03, para. 82. 148 Cf. ECHR, Case of Peers v. Greece. Judgment of 19 April 2001. Application No. 28524/95, para. 70-72. 149 para. 36 150 Cf. ECHR, Case of Karalevicius v Lithuania. Judgment of 7 April 2005. Application No. 53254/99, Cf. CPT/Inf (2001) 16, 11th General Report, para. 29. 151 Cf. ECHR, Case of Mathew v. The Netherlands. Judgment of 29 September 2005. Application No. 24919/03, para. 199. 152 Cf. Standard Minimum Rules for the Treatment of Prisoners. Adopted by the First United Nations Congress on Prevention of Crime and Treatment of Offenders, held at Geneva in 1955, and approved by the Economic and Social Council through its Resolutions 663C (XXIV) of July 31, 1957 and 2076 (LXII) of May 13, 1977, Article 32(1). 153 154 Cf. Standard Minimum Rules for the Treatment of Prisoners, supra note 152, Article 31. Cf. Case of García Asto y Ramírez Rojas, supra note 144, para. 221; Case of Raxcacó Reyes, supra note 144, para. 95, and Case of Fermín Ramírez, supra note 144, para. 118.