A/HRC/12/24 page 16 47. Furthermore, paragraph 15 of the Standard Minimum Rules for the Treatment of Prisoners of 195564 provides that “prisoners shall be required to keep their persons clean, and to this end they shall be provided with water and with such toilet articles as are necessary for health and cleanliness”. The United Nations Rules for the Protection of Juveniles Deprived of their Liberty of 1990 also refer to “sanitary installations”, specifying that they “should be so located and of a sufficient standard to enable every juvenile to comply, as required, with their physical needs in privacy and in a clean and decent manner”.65 48. At the regional level, the Inter-American Commission on Human Rights has heard several cases involving the State duty to ensure general conditions of health, hygiene and sanitation in prison or custodial facilities.66 In Europe, in the case of Melnik v. Ukraine,67 the European Court of Human Rights found that the overcrowding of prison cells, inadequate medical care and unsatisfactory conditions of hygiene and sanitation, taken together with the duration of detention, amounted to degrading treatment. 49. At the national level, a court in Fiji found lack of access to adequate sanitation in prisons to amount to cruel, inhuman and degrading treatment, finding a breach not only of the Fijian Constitution, but also of the Standard Minimum Rules for the Treatment of Prisoners.68 50. International humanitarian law also particularly refers to access to sanitation for detainees.69 CCPR/C/79/Add.120 (Mongolia), para. 12; CCPR/CO/83/KEN (Kenya), para. 19; CCPR/C/COD/CO/3 (Democratic Republic of the Congo), para. 20; CCPR/C/79/Add.121 (Guyana), para. 17; CCPR/C/79/Add.83 (Jamaica), para. 13; CAT/C/CR/33/3 (United Kingdom), para. 4; and CAT/C/NPL/CO/2 (Nepal), para. 31. 62 Mission to Indonesia, A/HRC/7/3/Add.7, para. 68; Mission to Togo, A/HRC/7/3/Add.5, paras. 42; Appendix, paras. 3, 31, 46-47, 70 and 95; and Mission to Nigeria, A/HRC/7/3/Add.4, paras. 37, Appendix, paras. 41, 95, 101 and 110. 63 Mission to Equatorial Guinea, A/HRC/7/4/Add.3, para. 83. 64 The United Nations Economic and Social Council resolutions 663 C (XXIV) of 31 July 1957 and 2076 (LXII) of 13 May 1977. 65 General Assembly resolution 45/113 of 14 December 1990, para. 34. 66 Inter-American Commission on Human Rights, Paul Lallion v. Grenada, report No. 55/02, Merits, Case 11.765, 21 October 2002; and Benedict Jacob v. Grenada, report No. 56/02, Merits, Case 12.158, 21 October 2002. 67 Case of Melnik v. Ukraine, European Court of Human Rights, Application No. 72286/01, judgement of 28 March 2006. 68 Sailasa Naba and others v. the State, High Court of Fiji, No. HAC0012 of 2000L, judgement of 4 July 2001.