iii. Engage with Bar Council and other relevant stakeholders to discuss the possibility of extending the National Legal Aid Scheme to include immigration cases involving refugees, asylum seekers and stateless persons. iv. In order to move the above strategies forward, three groups will be established and each tasked to address the following areas respectively: a. ATD for Children and Other Vulnerable Groups. b. Arrest, Detention and Release Procedures. c. Detention Standards. Moving forward, the working group on Immigration Detention hosted by UNHCR (which consists of key stakeholders including SUHAKAM) will have meetings to discuss the establishment of the multi-stakeholder groups and further action to be taken. As an initial step, SUHAKAM recommends that all unaccompanied children who are in immigration detention centers be released into a civil society run shelters as part of a pilot ATD project for children. SUHAKAM hopes that such measures will then be widely implemented and applied for all children who are in immigration detention or are found by the enforcement authorities. This is to ensure that the best interests of the child are upheld. 3. Children under preventive detention SUHAKAM reiterates its stance that detention without trial is a serious human rights violation and that laws that allow for such detention should be repealed. SUHAKAM is concerned that children have been detained using archaic laws such as POCA 1959. During SUHAKAM’s visit to the Kluang Prison on 19 July, a total of 39 juveniles were among the detainees. SUHAKAM interviewed some of them and were alerted to two serious allegations of chain remand, police brutality and forced confession. SUHAKAM stresses that such incidents go against the very principles of human rights. The Federal Constitution guarantees the right to be free from torture, to be presumed innocent until proven guilty and to have access to a fair trial. In particular, Article 5 of the Constitution guarantees the personal liberty of all persons and, if arrested, they must be informed on the grounds of arrest, allowed legal representation and produced before a magistrate within 24 hours. In addition, the Federal Constitution provides that any allegation of unlawful detention must be brought before a judge. However, under POCA, any detention is not subject to judicial review. With respect to allegations of police brutality, Section 330 of the Penal Code is clear that voluntarily causing hurt for the purpose of obtaining a confession is an offence punishable by law. 102 SUHAKAM ANNUAL REPORT 2018