Australian Human Rights Commission Submission to the UN Committee On The Elimination Of Racial Discrimination, 30 October 2017 have revealed fundamental problems with the structural design of the Northern Territory youth detention centres. The NT Royal Commission has heard concerns about the age and unhygienic conditions of the detention centres, their inappropriate design, the absence of privacy and the lack of windows for natural light and ventilation.115 98. The Royal Commission will deliver its final report on 17 November 2017. Recommendation 22: That the Australian Government, with the Northern Territory Government, swiftly consider the implementation of its response to the recommendations of the Royal Commission into the Protection and Detention of Children in the Northern Territory once its final report is delivered. The Commission considers this issue to be of such importance that the Committee should request an update from the Australian Government on progress in 12 months time. (c) Deaths in police custody 99. The issue of Aboriginal and Torres Strait Islander deaths in police custody and in prison has been cause for alarm for several decades. The 25 year anniversary of the recommendations of the Royal Commission into Aboriginal Deaths in Custody was in 2016.116 The Commission is concerned that the issue of deaths in police custody remains a serious issue. Nationally in 2014– 15, there were 11 deaths in police custody, of which five were Aboriginal and Torres Strait Islander deaths.117 100. The Commission notes the death of Cameron Doomadgee (known posthumously as Mulrunji) in police custody in 2004 on Palm Island and its aftermath and directs attention to issues of discriminatory police practices, as discussed in section 7 below. 101. The Commission also refers to ‘paperless arrest’ laws in the Northern Territory, which provide police with the power to detain a person for up to four hours (or longer if the person is intoxicated) if they suspect the person has committed or is about to commit an ‘infringement notice offence’ (a minor offence).118 The Commission considers that ‘paperless arrest’ laws lead to the unnecessary locking up of Aboriginal and Torres Strait Islander people and are inconsistent with the recommendations of the Royal Commission into Aboriginal Deaths and Custody.119 Family/domestic violence (CERD article 5 & Declaration article 22) 102. Aboriginal and Torres Strait Islander women are particularly at risk of violence.120 They are hospitalised for family violence-related assault at 30 times the rate of non-Indigenous women.121 Aboriginal and Torres Strait Islander children are overrepresented as child victims of physical assault and sexual assault in a residential location.122 The issue of violence against Aboriginal and Torres Strait Islander women and children remains a national 21