
Both common sense and the standards of international organisations say the same thing: an absence of complaints in a prison is not a sign of well-being. It is the first and most alarming signal that the complaints mechanism is not working, and that people are either afraid to complain, do not believe it will change anything, or simply have no real opportunity to do so.
The European Committee for the Prevention of Torture (CPT), in its standards on complaints mechanisms, expressly emphasises that a low number of complaints should not be taken as proof that there are no problems. On the contrary, it may indicate distrust of the system, fear of reprisals, or an inaccessible procedure. The United Nations Standard Minimum Rules for the Treatment of Prisoners (the Nelson Mandela Rules, Rules 56–57) and the European Prison Rules (Rule 70) require that every person deprived of liberty have a real, safe and confidential opportunity to lodge a complaint, and that such complaints be dealt with promptly and on the merits. Anyone who has ever been inside a pre-trial detention centre knows that there is always something to complain about: the conditions, the food, medical care, the attitude of staff, overcrowding.
And now – the facts.
After a months-long court dispute and dozens of letters, I have finally received an official reply from the State Institution “Odesa Pre-Trial Detention Centre” to the question: how many complaints from persons held in the Odesa SIZO were received by the administration of the institution each year from 2010 to 2026, and what proportion of them were found to be well-founded?
The institution’s reply: in the period from 2010 to 2026, the administration received the following from persons held in the institution: 1 complaint – in 2024;
2 complaints – in 2026.
That is all. Three complaints in seventeen years. In a facility through which thousands of people pass every year. In a detention centre that has for years featured in judgments of the European Court of Human Rights concerning inadequate conditions of detention.
One could, of course, believe that everything in the Odesa SIZO is so flawless that from 2010 to 2023 not a single person had a single grievance against the administration. But I propose a different reading. This reply is not a report of well-being. It is, in essence, a confession by the Odesa Pre-Trial Detention Centre as to the real state of affairs: either complaints are not being registered, or people do not dare to submit them, or the complaints system exists only on paper. Each of these possibilities points to a systemic problem, and each requires a response from the Ministry of Justice.
Where there are no complaints, there is no oversight. And where there is no oversight, room opens up for arbitrariness.