{"id":1834,"date":"2019-11-08T08:00:32","date_gmt":"2019-11-08T13:00:32","guid":{"rendered":"https:\/\/journals.law.harvard.edu\/hrj\/?p=1834"},"modified":"2020-06-06T17:28:11","modified_gmt":"2020-06-06T21:28:11","slug":"a-case-study-of-solitary-confinement-practice-in-turkey-neslihan-ekinci","status":"publish","type":"post","link":"https:\/\/journals.law.harvard.edu\/hrj\/2019\/11\/a-case-study-of-solitary-confinement-practice-in-turkey-neslihan-ekinci\/","title":{"rendered":"A Case Study of Solitary Confinement Practice in Turkey: Neslihan Ekinci"},"content":{"rendered":"

A Case Study of Solitary Confinement Practice in Turkey: Neslihan Ekinci<\/strong><\/p>\n

Article by Burak Haylamaz<\/p>\n

 <\/p>\n

Introduction<\/strong><\/p>\n

Neslihan Ekinci was the first female General Secretary of the Supreme Board of Judges and Prosecutors (HSYK) in Turkey. She had served as a judge for 25 years until she was dismissed by the Turkish government shortly after an attempted coup<\/em> d\u2019\u00e9tat <\/em>on July 15, 2016.[1]<\/a> She was later arrested on July 18, 2016 because of her alleged affiliation with those responsible for the attempted coup<\/em> and membership in an alleged \u201cterrorist organization.\u201d Ekinci was imprisoned for 29 months, 22 of which were spent in solitary confinement. During this time, prison authorities failed to provide any written decision justifying her confinement despite an advisory report from a prison psychologist that authorities must stop isolating her in a separate cell due to the potential for permanent damage to her mental health.<\/p>\n

This paper will focus on Neslihan Ekinci\u2019s solitary confinement as a case study to examine the legality of this treatment under both the Turkish legal system and the European Convention of Human Rights (ECHR).[2]<\/a> The paper will argue that Neslihan Ekinci\u2019s solitary confinement is illegal for two reasons: first, there is no legal basis for solitary confinement with respect to Ekinci\u2019s case proceedings, and it is thus directly in contradiction with the Turkish Constitution; and second, Ekinci\u2019s treatment fulfills the definition of torture prescribed under the ECHR and acknowledged under the Turkish legal system.<\/p>\n

Legal Authority (Procedural Violations)<\/strong><\/p>\n

Solitary confinement has historically been used in a limited manner as a disciplinary security measure against sentenced individuals in the Turkish legal system.[3]<\/a> In order to be subjected to it, the detainee must act contrary to law, regulations, or any order of the penal institution. However, the Turkish National Assembly enacted a new law\u2014Law No. 5275\u2014regarding the execution of penalties and security measures in 2004.[4]<\/a> The foremost amendment to this law prescribes solitary confinement as a punishment for those who hold a sentence of life imprisonment.[5]<\/a> Accordingly, the convict shall be accommodated in a \u201csingle room\u201d and have the right to walk and exercise in open air for one hour each day. In the context of Neslihan Ekinci\u2019s case, Law No. 5275 does not allow for her solitary confinement.<\/p>\n

 <\/p>\n

According to Article 4 of Law No. 5275, sentences of conviction shall not be executed unless they are finalized.[6]<\/a> Thus, the execution of penalties and security measures are attached to the finalized sentence of the conviction. However, no finalized sentencing decision was given for Ekinci. To date, she has only ever been in the pre-trial detention process. Yet even though Turkish law does not prescribe solitary confinement as a punishment or security measure for detainees whose sentences have not been finalized, Ekinci was continuously isolated and held incommunicado<\/em>. Therefore, there was no legal basis for exercising solitary confinement as to Ekinci in the Turkish criminal legal system. Consequently, the unlawful actions of prison authorities towards a former judge must have legal consequences.[7]<\/a><\/p>\n

Article 137 of the Turkish Constitution regulates unlawful legal action.[8]<\/a> If a civil servant finds out that an order from her superior is contrary to the provisions of Turkish by-laws, presidential decrees, laws, or the Constitution, she must not carry out the order and must inform the superior about its inconsistency with law. If her superior insists on the order by renewing it in writing, then she may execute the order, yet cannot be held responsible.<\/p>\n

As seen supra<\/em>, holding Ekinci in solitary confinement violates Article 4 in conjunction with Article 25 of Law No.5275. Thus, since no legal basis justified the exercise of solitary confinement, any public servant involved in the execution of solitary confinement was legally obligated not to carry out this measure and instead inform a superior about the inconsistency between the penal or security measure and the legislation. In doing so, an inferior officer would have escaped the responsibility of performing this illegal action so long as their superior insisted on imposing the measure in writing. In such a scenario, only the superior would have been held responsible for the action. However, in Ekinci\u2019s case, an inferior officer cannot disclaim responsibility from the exercise of the measure because she was placed in solitary confinement without any written decision from prison authorities.[9]<\/a> In other words, there is no evidence that an inferior officer asked for the written insistence of the prison governor to execute the solitary confinement measure. Hence, anyone involved in the execution of solitary confinement of Ekinci acted contrary to the Constitution and general principles of legality.<\/p>\n

Furthermore, Article 137 paragraph 2 of the Turkish Constitution states that \u201c[a]n order which in itself constitutes an offence shall under no circumstances be executed; the person who executes such an order shall not evade responsibility.\u201d[10]<\/a> Thus, if the execution of solitary confinement constitutes an offense under the Turkish Criminal Code, this order must not be executed under any circumstances and any person involved in administering that punishment must bear responsibility.<\/p>\n

Act as Torture (Substantive Violations)<\/strong><\/p>\n

Since Ekinci suffered both physically and mentally for 22 months due to the prison authorities\u2019 decision, the decision to subject her to solitary confinement may fall within the category of inhuman or degrading treatment, or torture offenses proscribed by Article 3 of the European Convention on Human Rights. The Convention imposes both positive and negative obligations on contracting states. With respect to the positive obligations, contracting states must secure the effective enjoyment of the rights enshrined under the Convention.[11]<\/a> In the context of Article 3, a state is obliged to ensure the protection of the bodily integrity and health of individuals against any possible harm.[12]<\/a> On the other hand, the negative obligations require contracting states to refrain from any action that damages a person\u2019s physical health or causes mental or psychological harm.[13]<\/a><\/p>\n

The rights enshrined in Article 3 of the ECHR are absolute: there is no room for derogation or limitation by law. By contrast, qualified rights like those enshrined in Article 8 of the ECHR (e.g.<\/em>, the right to respect for private and family life) allow restrictions or limitations provided that the interference is prescribed by law and necessary for the function of a democratic society.[14]<\/a> Thus, rights rooted in Article 3 continue to apply during times of war or public emergencies and regardless of any derogation to the ECHR made by a state. Under the state of emergency, Turkey submitted a formal notice of derogation to the ECHR without specifying the articles that it intended to suspend.[15]<\/a> Considering that Article 3 does not allow derogation, the question arises: by putting Ekinci in solitary confinement, did Turkey infringe on the negative obligations imposed upon it by the ECHR?<\/p>\n

The Convention itself does not provide a definition for torture or inhuman treatment. However, the European Court of Human Rights defined what constitutes torture in Gafgen v. Germany<\/em>,[16]<\/strong><\/em><\/a> a case that referenced Article 1 of the Convention Against Torture (CAT).[17]<\/a> Accordingly, there are two elements of torture: (i) the infliction of severe mental or physical pain or suffering; and (ii) the intentional or deliberate infliction of pain with a specific purpose, such as\u00a0 gaining information, punishment, or intimidation.[18]<\/a> Turkish law has acknowledged this definition[19]<\/a> and has codified it under Article 94 of the Turkish Criminal Code, which prescribes a penalty of imprisonment for a term of three to twelve years to a public officer involved in torture.[20]<\/a> Thus, if treatment towards Ekinci constitutes torture under that definition, then any public officer involved in that treatment cannot escape liability according to Article 137 of the Constitution because this unlawful order constitutes an offense per se<\/em> under the Turkish Criminal Code.<\/p>\n

Huseyin Ekinci, Neslihan Ekinci\u2019s husband and the former chief reporter of the Constitutional Court, wrote a letter to the President of the Constitutional Court, Professor Dr. Z\u00fcht\u00fc Arslan on May 24, 2017 to illustrate the illegality of the treatment of his wife. Huseyin Ekinci was also kept in detention.[21]<\/a> In his letter, Huseyin Ekinci reported that his wife was kept in solitary confinement for 10 months (twenty-three months until the end of the measure) in a 3.5 m2<\/sup> room. During this time, she was allowed to go outside for only forty-five minutes per day, and communication was prohibited. She was forbidden to write or receive letters.[22]<\/a> In March 2017, his wife was taken to the Bakirkoy Hospital for Health of the Spirit and Illnesses of the Nerves after showing symptoms of major depression, including eighteen hours of crying and a nervous breakdown.[23]<\/a> Huseyin Ekinci reported that his wife\u2019s doctor issued a report strongly advising prison authorities to transfer her from a single room to a dormitory because of the risk of permanent mental damage and noted that she could be expected to take several medications for the rest of her life as a result of her experience. As evidenced by her husband\u2019s letter and her doctor\u2019s report, it is clear that ill treatment at the hands of prison officials caused Neslihan Ekinci considerable fear and mental suffering. Therefore, the first element of torture\u2014infliction of mental or physical pain or suffering\u2014is fulfilled.<\/p>\n

With respect to the second element, ill-treatment must be deliberately carried out with a purposive element in order for it to be classified as torture.[24]<\/a> In Crino and Renne v. Italy<\/em>, the European Court of Human Rights held that ill-treatment inflicted on victims who were placed in solitary confinement amounted to torture because the acts were not confined to one particular moment but had instead been deliberate and carried out in a premeditated and organized manner.[25]<\/a> The court also found that the victims\u2019 placement in solitary confinement intensified their feelings of helplessness and fear.[26]<\/a> To assess whether there was a purposive element in Neslihan Ekinci\u2019s case, it is necessary to focus on the decision to subject her to solitary confinement<\/p>\n

According to Article 186 of the Regulation on the Administration of the Penal Institutions and the Execution of Penalties and Security Measures, the Board of Administration and Monitoring is charged with determining the room in which a person will stay after conviction.[27]<\/a> The decision to place Neslihan Ekinci in solitary confinement was taken up by the Board of Administration and Monitoring of the Tekirdag Penal Institution, but was not issued in writing.[28]<\/a> Thus, the decision to place her in solitary confinement cannot be effectively challenged because there was no written decision.[29]<\/a> The motivation behind this penal institution practice is clear: there is no discernible reason not to issue a written decision other than to prevent legal challenges to the government\u2019s authority to incarcerate people in solitary confinement.[30]<\/a> Moreover, one could reasonably infer that solitary confinement imposed on those suspected of the coup attempt is motivated by the desire for retaliation or an attempt to gather information.[31]<\/a> Thus, there is a strong indication that these detainees have been routinely exposed to punitive measures that exceed the bounds of permissible disciplinary or security measures. In the eyes of the ECHR, the existence of a broader pattern of abuse in penal institutions indicates the existence of a purposive element underlying the ill-treatment.[32]<\/a>\u00a0 Thus, one could conclude that the second element of torture is also fulfilled insofar as the decision of the ill-treatment against Neslihan Ekinci could not be legally challenged, which reflects the intentional infliction of the pain towards her. Besides, there is a generalized practice by the prison authorities to punish detainees which allegedly belong to a certain group.[33]<\/a> Therefore, the illegal treatment by Tekirdag Penal Institution falls under the definition of torture both in Turkish criminal law[34]<\/a> and under ECHR case law. Since this unlawful order constitutes torture, any person taking part in this treatment cannot escape liability pursuant to Article 137 of the Turkish Constitution. Consequently, in Neslihan Ekinci\u2019s case, Turkey did not comply with its obligations under the ECHR, and prison authorities breached Turkish penal law.<\/p>\n

Conclusion<\/strong>\u00a0<\/strong><\/p>\n

The case study of Neslihan Ekinci indicateshat Turkey has not taken steps towards the true path. Several organizations, including Amnesty International and Human Rights Watch, have voiced concerns about inhuman and degrading treatment and torture in Turkey, especially after the coup<\/em> attempt in 2016. The treatment against Ekinci is paradigmatic of the systematic pattern of punishing those allegedly linked to the coup<\/em> attempt. Solitary confinement is consistently used for this purpose by Turkish authorities even though there is no sentence given to the person in question. The motives behind this measure are clear: to eliminate, punish, and demotivate any dissident. However, the fundamental rights of today\u2019s political dissidents in Europe are protected under international law. All states are obliged to refrain from certain activities, including torture or inhuman treatment. As explained in this paper, the prolonged implementation of solitary confinement without appeal falls under the scope of the negative obligation prescribed in Article 3 of the ECHR, i.e.<\/em>, the prohibition of torture. It is essential that Turkey embrace the rights and principles enshrined in the ECHR and its legal system instead of refusing to comply with its obligations.<\/p>\n

 <\/p>\n

Bibliography<\/strong>\u00a0<\/strong><\/p>\n

Primary Sources:<\/u><\/p>\n

Constitution of the Republic of Turkey<\/p>\n

Law No. 26131; Ceza \u0130nfaz Kurumlar\u0131 ile Tevkifevlerinin Y\u00f6netimi\u00a0ve Cezalar\u0131n\u00a0\u0130nfaz\u0131na Dair T\u00fcz\u00fck<\/p>\n

Law<\/a> No.5275; Turkish Criminal Code<\/p>\n

Law No. 2006\/10218; Regulation on the Administration of the Penal Institutions and the Execution of Penalties and Security Measures<\/p>\n

G\u00e4fgen v. Germany<\/em>, No.22978\/05, Judgement, 1 June 2010<\/p>\n

Crino and Renne v. Italy<\/em>, Nos. 2539\/13 and 4705\/13, Judgement, 26 October 2017<\/p>\n

Secondary Sources:<\/u><\/p>\n

Zweig 2006<\/strong><\/p>\n

Stefan Zweig,\u00a0Chess: A Novel<\/em>, translated by Anthea Bell, London, Penguin Classics, 2006.<\/p>\n

Kinney 2016<\/strong><\/p>\n

Drew Holland Kinney, \u2018Civilian Actors in the Turkish Military Drama of July 2016<\/em>\u2019 (2016) EMPN No.10<\/p>\n

Boillat 2004<\/strong><\/p>\n

Philippe Boillat, \u2018The European Convention on Human Rights at 60: Building on the Past, Looking to the Future\u2019<\/em>, Human Rights and Legal Affairs of the Council of Europe, 2004.<\/p>\n

Council of Europe 2018<\/strong><\/p>\n

Council of Europe, \u2018Guide on Article 15 of the European Convention on Human Rights, Derogation in time of emergency\u2019, 30 April 2018.<\/p>\n

Gudjonsson 2003<\/strong><\/p>\n

Gisli H. Gudjonsson, \u2018The Psychology of Interrogations and Confessions: A Handbook\u2019<\/em>, Wiley Publishing, 2003.<\/p>\n

\u0130nsan Haklar\u0131 Derne\u011fi 2017<\/strong><\/p>\n

\u0130nsan Haklar\u0131 Derne\u011fi \u0130stanbul \u015eubesi, \u20181 Ocak- 30 Haziran 2017 Marmara B\u00f6lgesi \u0130nsan Haklar\u0131 \u0130hlalleri Raporu\u2019, <\/em>Istanbul, 2017.<\/p>\n

Working Party on Arbitrary Detention 2019<\/strong><\/p>\n

Human Rights Council Working Group on Arbitrary Detention, A\/HRC\/WGAD\/2018\/78, 2019.<\/p>\n

 <\/p>\n

 <\/p>\n

[1]<\/a> Please see Article 3 of the State of Emergency Decree No. 667 for the legal basis of this dismissal.<\/p>\n

[2]<\/a> Stockholm Center for Freedom, \u201cPurge-Victim Judge Couple Reunited with Daughter After 29 Months in Turkish Prison on Coup Charges<\/em>\u201d, November 13th<\/sup>, 2018.<\/p>\n

[3]<\/a>Ceza \u0130nfaz Kurumlar\u0131 ile Tevkifevlerinin Y\u00f6netimi\u00a0ve Cezalar\u0131n\u00a0\u0130nfaz\u0131na Dair T\u00fcz\u00fck<\/em>, Art. 161, http:\/\/www.resmigazete.gov.tr\/eskiler\/2006\/04\/20060406-1.htm archived at<\/em> https:\/\/perma.cc\/5294-A9Z3.<\/p>\n

[4]<\/a> The Law on the Execution of Penalties and Security Measures<\/em>, Law<\/a> No.5275, http:\/\/www.lawsturkey.com\/law\/the-law-on-the-execution-of-penalties-and-security-measures-5275 archived at<\/em> https:\/\/perma.cc\/R5C6-G6RH<\/p>\n

[5]<\/a> Article 25 of the Law No. 5275.<\/p>\n

[6]<\/a> Article 4 of Law No.5275.<\/p>\n

[7]<\/a> Article 137 of the Constitution of the Republic of Turkey 1982.<\/p>\n

[8]<\/a> Constitution of the Republic of Turkey, Art. 137, https:\/\/global.tbmm.gov.tr\/docs\/constitution_en.pdf<\/a> archived at https:\/\/perma.cc\/DL8V-J6V5.<\/p>\n

[9]<\/a> \u0130nsan Haklar\u0131 Derne\u011fi \u0130stanbul \u015eubesi, 1 Ocak- 30 Haziran 2017 Marmara B\u00f6lgesi \u0130nsan Haklar\u0131 \u0130hlalleri Raporu,<\/em> 28, June 30, 2017, http:\/\/www.ihd.org.tr\/wp-content\/uploads\/2017\/10\/2017-6-Ayl%C4%B1-rapor-1.pdf, page 28, archived at<\/em> https:\/\/perma.cc\/J62X-3T5M<\/a>. Please also see Yeni Asya, \u201cHukumsuz, Hapiste 8 Mevsim<\/em>\u201d, Mayis 2018.<\/p>\n

[10]<\/a> Constitution of the Republic of Turkey, Article 137, https:\/\/global.tbmm.gov.tr\/docs\/constitution_en.pdf<\/a> archived at https:\/\/perma.cc\/DL8V-J6V5.<\/p>\n

[11]<\/a> European Court of Human Rights, \u201cPositive Obligations under the ECHR: A Guide to the Implementation of the ECHR<\/em>\u201d, Council of Europe, Human Rights Handbooks, No. 7, page 6.<\/p>\n

[12]<\/a> European Court of Human Rights, \u201cThe Prohibition of Torture: A Guide to the Implementation of Article 3 of the ECHR<\/em>\u201d, Council of Europe, No. 6, page 36.<\/p>\n

[13]<\/a> G\u00e4fgen v Germany<\/em> Application No 22978\/05, Merits, 1 June 2010, at para. 89.<\/p>\n

[14]<\/a> European Court of Human Rights, Guide on Article 15 of the European Convention on Human Rights, Derogation in time of emergency, April 30, 2018, para 25. Please also see Council of Europe, \u201cThe Prohibition of Torture: A Guide to the Implementation of Article 3 of the ECHR<\/em>\u201d, No. 6, page 19.<\/p>\n

[15]<\/a> Council of Europe Communication; Ref. DC 132 (2016).<\/p>\n

[16]<\/a> G\u00e4fgen v Germany<\/em> Application No 22978\/05, Merits, 1 June 2010, at paras. 88-90.<\/p>\n

[17]<\/a> Article 1 of the Convention against Torture defines torture as any act by which severe pain or suffering, whether mental or physical, is intentionally inflicted on a person for a purpose by a person who is acting in an official capacity.<\/p>\n

[18]<\/a> Council of Europe, \u201cThe Prohibition of Torture: A Guide to the Implementation of Article 3 of the ECHR<\/em>\u201d, No. 6, page 12.<\/p>\n

[19]<\/a> TBMM Insan Haklari Inceleme Komisyonu, \u201cIskencenin Onlenmesine Dair Brilesmis Milletler Sozlesmesi<\/em>\u201d, 2011, http:\/\/www.tbmm.gov.tr\/komisyon\/insanhaklari\/pdf01\/37-51.pdf, page 28, (08.03.2011).<\/p>\n

[20]<\/a> Article 94 of the Turkish Criminal Code.<\/p>\n

[21]<\/a> Tutuklu Basrap\u00f6rt\u00f6rden AYM Ba\u015fkan\u0131na Mektup: M\u00fcebbet Alanlara Uygulanmayan \u0130nfaz E\u015fime Uygulan\u0131yor<\/em>, Tr724, June 30, 2017, http:\/\/www.tr724.com\/tutuklu-basraportorden-aym-baskanina-agirlastirilmis-muebbet-alan-mahkumlara-uygulanmayan-infaz-hakim-esime-uygulaniyor\/ archived at<\/em> https:\/\/perma.cc\/H9V8-M3FW.<\/p>\n

[22]<\/a> Ibid.<\/em><\/p>\n

[23]<\/a> R\u00fc\u015fvet\u00e7i Hakim\u2019in Y\u0131kt\u0131\u011f\u0131 Ailenin Dram\u0131n\u0131 K\u0131zlar\u0131 Anlatt\u0131: Annemi Ve Babam\u0131 Whatsapp Grubuna Sorup Tutuklad\u0131<\/em>, Tr724, Apr. 24, 2017, http:\/\/www.tr724.com\/rusvetci-hakim-akdemirin-yiktigi-bir-ailenin-dramini-kizlari-anlatti-annemi-ve-babami-whatsup-grubuna-sorarak-tutukladi\/ archived at<\/em> https:\/\/perma.cc\/DH4V-F63Q.<\/p>\n

[24]<\/a> G\u00e4fgen v Germany<\/em> Application No 22978\/05, Merits, 1 June 2010, at para. 90.<\/p>\n

[25]<\/a> Case of Crino and Renne v. Italy<\/em>, Nos. 2539\/13 and 4705\/13, Judgement, 26 October 2017, para 83 in conjunction with para 86.<\/p>\n

[26]<\/a> Case of Crino and Renne v. Italy<\/em>, Nos. 2539\/13 and 4705\/13, Judgement, 26 October 2017, paras 80-85.<\/p>\n

[27]<\/a> Article 186 of the Regulation on the Administration of the Penal Institutions and the Execution of Penalties and Security Measures, Ceza \u0130nfaz Kurumlar\u0131n\u0131n Y\u00f6netimi \u0130le Ceza Ve G\u00fcvenlik Tedbirlerinin \u0130nfaz\u0131 Hakk\u0131nda T\u00fcz\u00fck, Law No. 2006\/10218. Available via <http:\/\/www.resmigazete.gov.tr\/eskiler\/2006\/04\/20060406-1.htm><\/p>\n

[28]<\/a> \u0130nsan Haklar\u0131 Derne\u011fi \u0130stanbul \u015eubesi, 1 Ocak- 30 Haziran 2017 Marmara B\u00f6lgesi \u0130nsan Haklar\u0131 \u0130hlalleri Raporu,<\/em> 28, June 30, 2017, http:\/\/www.ihd.org.tr\/wp-content\/uploads\/2017\/10\/2017-6-Ayl%C4%B1-rapor-1.pdf, page 28, archived at<\/em> https:\/\/perma.cc\/J62X-3T5M<\/a>. Please also see Yeni Asya, \u201cHukumsuz, Hapiste 8 Mevsim<\/em>\u201d, Mayis 2018.<\/p>\n

[29]<\/a> Ibid<\/em>.<\/p>\n

[30]<\/a> The similar incarceration has also been followed by the authorities against other members of the Court of Cassation without a written decision, e.g., Mr.Hamza Yaman and Mr.Mesut Budak. Please see Opinion No.78\/2018 concerning Hamza Yaman (Turkey), Human Rights Council Working Group on Arbitrary Detention, A\/HRC\/WGAD\/2018\/78, January 31st<\/sup>, 2019, paras. 12 and 90.<\/p>\n

[31]<\/a> H\u00fccre hapsi, OHAL sonras\u0131 devlet eliyle i\u015flenen bir su\u00e7a d\u00f6n\u00fc\u015ft\u00fc<\/em>, Grihat, Jul. 5, 2017, http:\/\/grihat.com\/hucre-cezasi-ohal-sonrasi-devlet-eliyle-islenen-bir-suca-donustu\/ archived at<\/em> https:\/\/perma.cc\/DEA9-3KU2.<\/p>\n

[32]<\/a> Case of Crino and Renne v. Italy<\/em>, Nos. 2539\/13 and 4705\/13, Judgement, 26 October 2017, paras. 84-86.<\/p>\n

[33]<\/a> H\u00fccre hapsi, OHAL sonras\u0131 devlet eliyle i\u015flenen bir su\u00e7a d\u00f6n\u00fc\u015ft\u00fc<\/em>, Grihat, Jul. 5, 2017, http:\/\/grihat.com\/hucre-cezasi-ohal-sonrasi-devlet-eliyle-islenen-bir-suca-donustu\/ archived at<\/em> https:\/\/perma.cc\/DEA9-3KU2.<\/p>\n

[34]<\/a> Article 94 of the Law No. 5275.<\/p>\n","protected":false},"excerpt":{"rendered":"

A Case Study of Solitary Confinement Practice in Turkey: Neslihan Ekinci Article by Burak Haylamaz   Introduction Neslihan Ekinci was the first female General Secretary of the Supreme Board of Judges and Prosecutors (HSYK) in Turkey. She had served as a judge for 25 years until she was dismissed by the Turkish government shortly after […]<\/p>\n","protected":false},"author":101946,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"site-sidebar-layout":"default","site-content-layout":"","ast-site-content-layout":"default","site-content-style":"default","site-sidebar-style":"default","ast-global-header-display":"","ast-banner-title-visibility":"","ast-main-header-display":"","ast-hfb-above-header-display":"","ast-hfb-below-header-display":"","ast-hfb-mobile-header-display":"","site-post-title":"","ast-breadcrumbs-content":"","ast-featured-img":"","footer-sml-layout":"","ast-disable-related-posts":"","theme-transparent-header-meta":"","adv-header-id-meta":"","stick-header-meta":"","header-above-stick-meta":"","header-main-stick-meta":"","header-below-stick-meta":"","astra-migrate-meta-layouts":"default","ast-page-background-enabled":"default","ast-page-background-meta":{"desktop":{"background-color":"var(--ast-global-color-5)","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-opacity":"","overlay-gradient":""},"tablet":{"background-color":"","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-opacity":"","overlay-gradient":""},"mobile":{"background-color":"","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-opacity":"","overlay-gradient":""}},"ast-content-background-meta":{"desktop":{"background-color":"var(--ast-global-color-4)","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-opacity":"","overlay-gradient":""},"tablet":{"background-color":"var(--ast-global-color-4)","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-opacity":"","overlay-gradient":""},"mobile":{"background-color":"var(--ast-global-color-4)","background-image":"","background-repeat":"repeat","background-position":"center center","background-size":"auto","background-attachment":"scroll","background-type":"","background-media":"","overlay-type":"","overlay-color":"","overlay-opacity":"","overlay-gradient":""}},"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-1834","post","type-post","status-publish","format-standard","hentry","category-online-journal"],"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/posts\/1834","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/users\/101946"}],"replies":[{"embeddable":true,"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/comments?post=1834"}],"version-history":[{"count":0,"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/posts\/1834\/revisions"}],"wp:attachment":[{"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/media?parent=1834"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/categories?post=1834"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/journals.law.harvard.edu\/hrj\/wp-json\/wp\/v2\/tags?post=1834"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}