The Independent Commission for Human Rights (ICHR) | Shadow report – Coordinate with local institutions to provide education to detained juveniles. In this context, current efforts are inadequate. o Women’s detention centres – Increase coordination and networking with community institutions and civil society organisations to rehabilitate and train women to help them take care of themselves before release. – Provide a gynaecological clinic or a female gynaecologist for female inmates independently of the general clinic. – In relation to the National Preventive Mechanism against Torture On 29 December 2017, the State of Palestine acceded to the Optional Protocol to the Convention against Torture (OPCAT), which aims at establishing a national preventive mechanism against torture (NPM). However, the legal framework for the NPM, namely the Law by Decree No. 25 of 2022 on the National Commission against Torture, was only enacted in mid-2022. Together with civil society groups, the ICHR submitted a position paper on the NPM establishment as mandated in the law by decree. The ICHR emphasises the following points, which run counter to the standards of independence and impartiality prescribed by the OPCAT: a) Many provisions of the law by decree undermine the principles of NPM independence. It views the NPM as a State institution and government agency, to which all laws and regulations on official institutions are applicable. The enactment also deems that the chairperson and staff members of the Commission against Torture as civil servants, who are subject to the Civil Service Law. Procurement and tendering transactions are governed by the Public Procurement Law, treating the Commission as a full government body. Every time, NPM members are appointed by the President based on a recommendation of the Council of Ministers, contradicting the State of Palestine’s obligations under the OPCAT. These require the adoption of the highest standards of transparency and independence. When NPM members are chosen, the same approach applicable to the selection of commissioners of national human rights institutions will be in place. Many irregularities deprive the NPM of independence, impartiality, and objectivity at all levels. b) The law by decree greatly undermines the independence, transparency, and impartiality of the National Commission against Torture, which is established in accordance with its provisions. The law by decree does not make available the legal tools the Commission needs to exercise its powers 12