80 Commission's Major Activities ● Use of excessive restraints on a prisoner during kidney dialysis Regarding the use of redundant restraints on a prisoner—one on the wrists and another on the ankles—during a kidney dialysis, the Commission concluded that the respondent had resorted to the practice of convenient custody based on an abstract risk without giving due consideration to the specific situation faced by the complainant, and that the use of excessive restraints went above the scope of minimum infringement and constituted excessive limitation of the complainant’s personal liberty specified under Article 12 of the Constitution. On 28 June, the Commission recommended the governor of Prison X to educate its officers, to ensure that due consideration is given to prisoners’ specific situations during outside medical treatment and to use restraints within the scope of minimum infringement, and to ensure good oversight. ● No outdoor exercise allowed for unconvicted detainees On 8 September, the Commission recommended the director of Detention Center X to take all possible measures to allow unconvicted prisoners to use the rooftop grounds for outdoor exercise. It also recommended the Minister of Justice to provide the necessary support to facilitate outdoor workout for detainees and to strengthen oversight. The Commission acknowledged that, compared to other prisons, the detention center has limited open space as it is a building-style correctional facility built in the city to enable efficient coordination with the courts, Public Prosecutors’ Office, and other related institutions. That said, it argued that there is room to make use of the grounds on the rooftop, and that the lack of guards and elevator, which the respondent claims as reasons for not allowing outdoor exercise for unconvicted prisoners, is a problem that the center must resolve with the relevant agencies through recruitment and facility improvement, and is thus not grounds for limiting the outdoor exercise of detainees. Based on these considerations, the Commission concluded that the respondent’s disallowing outdoor exercise for unconvicted detainees is a violation of the facility’s relevant regulations and an infringement of the dignity of the detainees, and their right to health specified under Article 10 of the Constitution.