who should not be subject to solitary confinement. When in solitary confinement access to basic necessities, including adequate food, light and exercise should never be denied. The same principles apply to solitary confinement for security reasons or protective purposes. Disappearances – ill-treatment of remaining family The disappearance of a person in circumstances engaging the responsibility of the State may constitute ill-treatment of close relatives of the disappeared individual. However, international bodies have been careful not to establish a general principle that ill-treatment will always be found in such a case. In Kurt v Turkey120 the ECHR held that the mother of a disappeared person was herself a victim of inhuman and degrading treatment because she had endured years of inaction on the part of the State authorities and years of knowing nothing of her son’s fate. However, in Cakici v Turkey121 the ECHR held that Kurt did not establish any general principle that a family member of a ‘disappeared person’ is thereby a victim of ill-treatment: Whether a family member is such a victim will depend on the existence of special factors which gives the suffering of the applicant a dimension and character distinct from the emotional distress which may be regarded as inevitably caused to relatives of a victim of a serious human rights violation. Relevant elements will include the proximity of the family tie – in that context, a certain weight will attach to the parent-child bond -, the particular circumstances of the relationship, the extent to which the family member witnessed the events in question, the involvement of the family member in the attempts to obtain information about the disappeared person and the way in which the authorities responded to those enquiries. The Court would further emphasise that the essence of such a violation does not so much lie in the fact of the ‘disappearance’ of the family member but rather concerns the authorities’ reactions and attitudes to the situation when it is brought to their attention. It is especially in respect of the latter that a relative may claim directly to be a victim of the authorities’ conduct.122 120 121 Kurt v Turkey, judgment of the ECHR, 25 May 1998. Cakici v Turkey, judgment of the ECHR, 8 July 1999. 86