Clement Okech, Deputy Director of Probation and Aftercare Services, Kenya
Introduction
Arriving at what may be considered a fair decision in sentencing requires several considerations beyond what is defined by law. Sentence disparities, lack of certainty,
disproportionate terms and overreliance on penal incarceration are some of the challenges that judicial officers grapple with. The courts in Kenya have for years applied non-discreet parameters in sentencing and in selecting offenders suitable for noncustodial sanctions owing to the wide sentencing discretions it enjoys. Similarly, correctional personnel in both custodial and noncustodial realms have had challenges with identifying discrete crime causal factors associated with individual offending behaviour which can then inform effective intervention decisions. The result has been recidivism and penal overcrowding with many of first time and young offenders graduating into adult criminality.
Probation officers in Kenya occupy a central and critical place in sentencing. They provide valuable information that help bridge the gap between penal law requirements and the requisite social interventions conducive to addressing criminal behaviour. This consequently enables the offloading of thousands of offenders to noncustodial measures.
This paper contextualizes the use of penal incarceration in Kenya as an effect of sentencing and punishment. It explores the role of probation officers in sentencing and how structured assessment of offenders is being used to better inform sentence decisions and eventual rehabilitation in both community and institutional corrections. It examines the foregoing within the Kenyan context and chronicles some of the recently introduced instruments of offender assessment and how this portends to advance sentencing and correctional interventions in Kenya. Finally, it discusses replicability scope to other jurisdictions.
Contextual Background
The World Prison Population report (2021) estimates the global prison population to be 10,771,20 out of which Africa contributes 1,194,497. Further, Kenya contributes to this figure with its 42,596 prisoners[1] This however includes pretrial population who unfortunately are un-convicted. In the same vein, Nigeria has 68,556 persons in its prisons[2]. The examination of this situation demands the answer to the question of whether penal overcrowding is a problem of prison size or a problem of decision to incarcerate. Penal institutions are said to be congested when the total number of inmates exceed the certified normal accommodation capacity[3]. Penal overcrowding is thus one of the serious challenges bedevilling many criminal justice systems in the world and in Africa where prison population is ever widening and the resources for countering the surge diminishing.
The Kenya justice system is largely adversarial, and application of the criminal law has the contribution of many stakeholders who, although may share common objectives of crime prevention, seem to be working at cross purposes, at least when it comes to the justification for imprisonment. The core criminal justice system in Kenya comprises the Judiciary, Police, Prosecution, Prisons, and Probation Services. All work independent end of each other but share common criminal justice goals. There are other non-state actors, the defence counsels and other professionals and welfare agencies who work for victims and children. These agencies are enjoined together through the National Council of the Administration of justice formation whose mandate is to develop and oversight the implementation of justice polices and the coordination of the justice systems at various service levels. This organ is replicated at County and court station levels through the Court User Committees[4].
The Judiciary is one of the three arms of government established under the Constitution of Kenya as an independent custodian of justice in Kenya. Its primary role is to exercise judicial authority given to it, by the people of Kenya[5]. The mission of the judiciary is to deliver justice fairly, impartially, and expeditiously, promote equal access to justice, and advance local jurisprudence by upholding the rule of law. In criminal justice proceedings, its role is in determining the guilt or innocence of those accused of violating the criminal laws and dispensing penalties in accordance with the penal policy spouses in various penal laws. One way in which the judiciary dispenses justice is through trial, conviction and sentencing or punishing an offender in accordance with the penal law, policy guidelines, and professional guidance. Both the penal code and the sentencing policy[6] allow the use of deterrent sentences and alternatives to imprisonment including probation orders and community service orders. Aside from the two, the sentencing legislation has other case disposal method including conditional discharge, fines, diversion, compensation, suspended sentence and forfeiture. The court may also employ other mechanism of solving disputes for instance restorative justice measures. Although the Kenyan penal policy leans more on custodial incapacitation especially with the introduction of some statutes prescribing determinate sentences[7], judicial officers still exercise wide discretionary powers in sentencing. Nevertheless, courts have been blamed for congesting the correctional facilities with person who may not necessarily deserve being in prison and have been blamed for excessive use of pre-trial detention, punitive (tough on crime) sentences, underuse of alternatives to imprisonment, rigid sentencing guidelines and generally preference for deterrence and preference for penal capacitation. This situation is exacerbated by high reoffending rates resulting from inadequate in-prison or community-based rehabilitation and reintegration programmes. In retrospect, introduction of probation system in Kenya in 1943 through a probation of offender’s ordinances was due to congestion of the few penal facilities that existed at that time. Since then, probation has worked closely with the courts at sentencing and other penal law decision making.
The Kenyan probation system has had a long history of working closely with the courts more than with other criminal justice agencies. This working relationship has a historical perspective right from probation evolution in England where it begun with the missionaries work at the London police courts since the beginning of the 20th Century till the advent of probation in the British colonies, Nellis, (2007)[8]. At that early stage, the need to work with the police courts was to divert delinquents from being sent to adult prisons where they would be contaminated and influenced into engaging in more serious crime upon release. Later, the enactment of the English Probation of Offenders Act of 1907, entrenched the welfare approach to probation work characterized by the maxim of ‘advice, assist and befriend’ allowing probation officers working with broad categories of offenders across all ages and offence types, (ibid). This humble beginning nurtured probation officers complementary work of judicial officers in fulfilling justice needs particularly during sentencing.
It is however worth noting that although Probation system has entrenched itself into the judicial sentencing process and decision making in Kenya for the past seven decades, only a limited number of offenders are referenced for presentence reports and even then, a sizable number are subsequently accorded community sentence. For instance, during the 2018/19 reporting period, a total of 16,629 probation order inquiries were made by officers and presentence reports prepared out of which 9,706 offenders were placed on probation orders. As for community service, in the same period a total of 29,542 cases were referred for CSO out of which 24,002 offenders were found suitable to serve their sentences under community service orders[9]. The many serious and complex and yet others being deemed ‘unsuitable ‘for community sentences have all contributed to apparent fewer number of offenders being placed on community sanctions. The other reasons being the emergence of determinate legislations and sheer increase in numbers of repeat offenders. nevertheless, the use of probation officers on bail and sentence decisions still seems to have increased over the past few years. One major reason for this is the introduction of evidence-based approaches in informing presentence by probation officers in response to what Easton and Christine (2008)[10] termed as sentencing upon risk of harm. This is where new approaches have been developed to support sentencing decisions to make more accurate and predictable and able to win the confidence of the justice users. Before delving into the role of probation officers in sentencing, it is important to discuss briefly sentencing and punishment aspects from a theoretical and Kenya policy perspectives.
Sentencing and Punishment
The effectiveness of the criminal justice system is largely judged based on the outcome of the sentencing process. a fair decision in sentencing is neither an easy nor straightforward process as several considerations come into play. While sentences are defined by law, their pronouncements are equally informed by theoretical underpinnings.
In the perception of the public, sentencing outcomes underpin the essence and effectiveness of the criminal justice process and further helps in budling public confidence in the system. Sentencing is the pronouncement of punishment of an offender found guilty and convicted by a competent court for a crime committed. The philosophical justification for punishment is conceived either as a sign of disapproval by the public for what the offender had done (retribution_) or a s a means of reducing the chances of the offender or another offender repeating the same, (utilitarianism), Hedderman, (2007)[11] The latter is construed from a positivist perspective and aims at deterring the commission of future offences through rehabilitation, deterrence, risk management and the more recently, restorative justice[12].
Punishment rests on the moral reasoning and condemnation of law infringement. Punishment is regulated by criminal law and is expressed by an organ vested with the authority in the criminal justice system, principally the courts. The modern and often expressed aim of sentencing is to impose punishment on an offender, reduce crime, reform offenders, protect the public and make reparation by the offender to victims affected by the offence (restorative Justice). The sentencing policy guidelines for the Kenyan judiciary These objectives may not explicitly be prescribed in the Kenyan penal statues but are imbedded in the constitution and sentencing policy guidelines and are often pronounced by the sentencers. The Kenyan sentencing policy guidelines are based on the principles of proportionality, equality, uniformity, parity, consistency, impartiality accountability and transparency, inclusiveness, respect for human rights and fundamental freedoms and adherence to domestic and international law with due regard to recognised international and regional standards on sentencing.[13] Although these principles reflect the aspiration expressed in the Bill of Rights embedded in the Constitution of Kenya, their total application remain elusive.
Most sentencing decisions, although meant to be informed by the sentencing policy and the law, have largely been based on discretionary powers of the court which often yield to incapacitation objective of sentencing without considering the salient individual factors that may be at play. On the other hand, it is the discretionary nature of sentencing in Kenya that gives room to probation officers to partake in the sentencing decision making process. Section 216 of the Criminal Procedure Code, inter alai, invites the court to request for any evidence to support the sentence or order, that it may make. Section 4 of the Probation of offenders Act on the Power of court to permit conditional release of offenders, equally provides the areas for the court to consider before making a probation order.
(1) Where a person is charged with an offence which is triable by a subordinate court and the court thinks that the charge is proved but is of the opinion that, having regard to youth, character, antecedents, home surroundings, health or mental condition of the offender, or to the nature of the offence, or to any extenuating circumstances in which the offence was committed, it is expedient to release the offender on probation, the court may—
(a) convict the offender and make a probation order; or
(b) without proceeding to conviction, make a probation order,
and in either case may require the offender to enter into a recognisance, with or without sureties, in such sum as the court may deem fit[14].
This is an old statute but still holds on probation ideals. Two issues stand out here, that there are many grounds upon which the court may release an offender on probation and secondly, that such an order may be granted without having to first convict an offender. A similar provision ties the High Court albeit that the offender has to be convicted. The forgoing must however be informed by a presentence report prepared by a probation officer. Presentence report have thus become a significant tool for judicial officers whenever they contemplate placing an offender on community supervision orders or just to help them make a plausible sentencing measure including imprisonment. Frequent engagement in this regard and increase in complex and serious crime coupled by the huge prison population have created more demand for presentence and bail reports from probation officers.
Presentence Inquiries and Role of Probation in Sentencing Decision Making
Since the advent of probation in Kenya, social inquiries have been one of its main features preceding any court sanctioned supervision of offenders. It was undertaken within what Garland, (1996) described as ‘penal welfarist’ approach to justice where individual and personal circumstances of the offender was given attention by the courts making probation officers more prominent in the courts. In Kenya, probation reports are, as they were then, diagnostic tool for officers to make assessment based on psychosocial case work. the reports afford the probation officer the opportunity to display their professional skill in assessing and predicting behaviour, Nash (2003)[15]
The social inquiry is a process of generating data and information on an offender for the purpose of documenting and understanding the attendant causes of behaviour related to the criminal events. Presentence reports provide advisory information to the courts with a view to the court making sentencing verdict including decisions on alternative measures to imprisonment. The investigations are conducted with aim of collating verifiable information and for writing various assessment reports including presentence reports. In sentencing decision making, social investigations help in:
- Formulating plausible theoretical explanation of the criminal behaviour of an offender
- Understanding the personality of the offender beyond the crime committed
- Developing a basis for intervention/rehabilitation
- Identifying resources required to effect change[16]
The inquiries aids in appraising the background, personality and conduct of the offenders in the light of the offence committed and what they think of their ill action, identifying the risk and criminogenic needs at play (and any positive protective factors or strengths), evaluating the seriousness of the offence and the impact on victims in order to determine a proportionate sanction, identifying the likely impact of a sentence on any dependants (children or any other dependent members of the (extended) family), engaging families, employers, partnership organizations and significant others in the community about the offender, gaining knowledge of the culture (for possible use during rehabilitation and rehabilitation or restorative justice) and resources available in the local communities and proposing cogent measures necessary to address the identified 'needs' and forestall risk of reoffending including an appropriate sentence. These have well been captured in the new provision is the amended Probation of Offenders Act (Revised, 2018) and further informed by international best practices. The United Nations Standard Minimum Rules for Non-Custodial Measures (The Tokyo Rules) provide for the preparation of a social inquiry report to the judicial authority by a competent authorized official or agency whose content would detail a person's pattern of offending and current offence. The report should be Factual, Objective and Unbiased. The UN Rules on the Treatment of Women Prisoners and Non-Custodial Measures for Women Offenders (The Bangkok Rules) supplement the Tokyo Rules and provide standards tailored to the background and needs of women offenders (see Rules 57-66 on sentencing and non-custodial measures and sanctions).[17]The UN Convention on the Rights of the Child (to which Kenya is a State Party) demands that courts must consider the best interests of the child when making a decision that concerns children. This means that the best interests of the child of an offender must be considered when sentencing.
The African Charter on the Rights and Welfare of the Child (to which Kenya is a State Party) provides that ‘States Parties…shall undertake to provide special treatment to expectant mothers and to mothers of infants and young children who have been accused or found guilty of infringing the penal law and shall in particular: (a) ensure that a non-custodial sentence will always be first considered when sentencing such mothers.’[18]
Furthermore, the Sentencing Policy Guidelines2016,[19] for judges and magistrates, include guidance relevant for probation officers, notably regarding sentencing options (Part II), categories of offenders requiring particular attention (Part III) and regarding the duties of probation officers (Part IV, paras. 22.8 – 22.16).
One main improvement in the presentence reports is that by law, issues of victim must also be incorporated. When conducting social inquiries and especially issues about the victims, the law demands of probation officers to inquire on what victims think of the action of the offender, whether they may be any room for reconciliation and any need of compensation, how the offence has impacted on the life of the victim, what are the emotional and financial impact of the offence on the victim and what protective measures may be necessary to forestall re-victimization
The forgoing, however, has prevailed over the years (and improved with the law), within the rubrics of criminal justice social work practice where presentence investigations advisory reports have for many years been based on clinical approaches whose vogue is fast fading. In place and taking the queue from numerical sciences, the quantitative and structured qualitative approaches have been introduced to improve on information provided to courts through presentence reports at sentencing and post-sentencing stages. The new approaches have largely been attributed to scientific growth in working with officers and entrenchment of evidence-based methods in correction work. Further, increase in crime and reoffending rates have a resulted in the need for courts adopt a more risk informed sentencing where greater requirement is on assessing risk of reoffending and potential harm.
Risk Needs Assessment and Sentencing
In the context of criminal justice, risk-based decision making involves weighing up community’s right to protection from the offender against the offender right to liberty or to the least necessary restriction, Hudson (2001)[20]. Indeed, the problem of not being able to predict potential risk has been blamed for overincarceration as a strategy to minimize risk, Easton, and Piper (2008)[21]. The new development in sentencing where greater thoughts are made on the idea of crime control aims at identifying the ‘dangerous’ offender and mitigating the potential risk, albeit, often through imprisonment. This notion largely points to minding about the past when sentencing and as such has been seen to perpetuate the incapacitation and deterrence reasoning about sentencing. The enactment of the many determinate penal laws is a reflection on this idea.
On the other hand, the utilitarian justification of crime control looks at risk assessment with the need to identify the reason behind criminal behaviour with a view to addressing them. It is in the latter though that probation service in Kenya has been able to introduce risk assessment instruments as tools for analysis and applying the assessment outcomes to the reports prepared to court and other penal release organs. Much as this is still a relatively new phenomenon in criminal justice in Kenya having been introduced in 2016, the potential and effect in shaping sentencing for utilitarian purposes is enormous.
Evidence based correctional practice on which presentence reporting is based is informed core assessment and rehabilitation principles. Risk principle: the degree of intervention required in each case should be related to an assessment of the risk of reoffending and the risk of serious harm. Needs principle: the intervention in each case should be targeted on those personal and social factors which are assessed as being likely to cause reoffending. Responsivity principle: the intervention should be based on methods which are demonstrably effective in reducing offending, and which are responsive to the culture, gender and learning styles of individual offenders. In addition to the above three (d) human service delivery and (e) adherence to the core clinical principles have equally been added to the list.
The presentence reports by probation officers trained on structured risk and needs assessment has created mixed reactions from sentencers and probation officers alike. Magistrates who have been sensitized on structured risk assessment have found presentence reports based on Risk-Needs-Responsivity (RNR) principles[22] to be more useful during sentencing. Magistrates and probation officers find the reports written upon RNR concepts to give better perspectives on the offenders and the court can point out key issues to consider and peg sentencing and or intervention around those issues. Probation officers using the tool point out that clinical methods of interviews are biased because they tend to appeal to one’s emotions, experience, and state of mind at the time of interviews. On the downside, officers have also pointed out that the RNR method if not carefully used can lead to monotonous reports. On the whole, systematic identification of offender risk and needs at sentencing has the potential of not only enabling judicial officers and correctional personnel to make more informed decision but also increases public confidence in sentencing and improvement of correctional outcomes.
Assessment and Correctional Interventions
In Kenya, assessing and developing a case plan or treatment plan is a daily event for probation officers working directly with offenders. Effective rehabilitation and supervision of offenders placed on various community supervision orders by the courts is dependant upon methodical diagnostic assessment of the risk factors and the drivers to criminality and, the array of interventions to address the problem. New assessment methods and principles underpinning different interventions have emerged and are integrated into the individual treatment plans.
The National Standards Manual requires of the supervising officer to draw a case plan based on the offender’s motivation and pattern of offending, the problems, needs and risk of reoffending and, any order requirements set out by the court. It equally requires of the officer to identify individual programmes designed to tackle the problems responsible for the offending behaviour. The application of these standards is further stipulated in the Quality Assurance/Standard Operating Procedure Manual thus directing both the management and practice on case planning and delivery
Individual Treatment Plan (ITP) or case plan, is a framework of planned actions based on assessments done meant to help address the criminogenic needs identified in an offender. The individual Treatment Plan (ITP) is thus a master plan for both the case manager and client that outlines and defines the course of treatment for offender undergoing any rehabilitation process in any of the correctional setting including in the institutions. It is an intervention case plan that identifies the cause of actions for each of the identified needs that has been clearly defined and systematically prioritized for implementation. It is a comprehensive and holistic plan that delineates each criminogenic need and precisely defines rehabilitation goals, objectives, actions/interventions, responsible persons / players, timeframe.
Rehabilitation and treatment of offenders require of case workers to use evidence-based tools and processes in their course of work. Just as it is important to have a standardized way of establishing criminogenic needs and implementing possible interventions using the RNR methodology, so it is equally imperative to have systematic way of treatment and rehabilitation delivery. Identifying each offender's most prominent criminogenic needs is a critical function that precedes the case planning procedures.
A raft of tools has been developed by the Probation and Aftercare Service to support assessment of offenders at presentencing and post placement period. As noted above, the utilitarian justification of sentencing is well supported with the use of structured assessment to inform the presentence reports. As such and with the support of developing partners, the department has been able to develop three tools, based on quantitative approach while one is based on structured profession judgement. However, only one of the tools (Tool ABC on RNR Assessment) has been validated and fully in used in nearly a third of the country. This is a generic adult assessment too which is used to assess both static and dynamic risk factors (criminogenic needs) and risk protective factors. The second tool is the RNA Tool for Youthful offenders. This tool has not been piloted and remain not in use. It is shaped along the level of service inventory Revised[23] and was meant for assessing child offenders. The most recently developed too is the one dubbed PK-RAVET which is a structured professional judgment tool (SPJ) used by probation officers to assess violent extremist offenders. This tool is currently under pilot as part of the process to validating its veracity and efficacy. All these tools have structured domains and ask questions related to the possible criminal behaviour. These tools are used during the assessment and rehabilitation process of an offender. The outputs from the tools inform case plans are instrumental in shaping the possibility of addressing criminal behaviour.
Replicability
The form of conducting social inquires and making a presentence report to precede sentencing was underpinned as a best practice way back in 1990[24]. This therefore means that this form of correctional officers’ support during sentencing is a universally accepted practice. However, the same source prevails upon jurisdiction to have trained officers to support community supervision of offenders and all those appertains to it. In this regard, the first component of assessment informed by social inquires alone need to be undertaken by trained staff. Further, and as the rules demand, the application of probation or other community release options must be based on a national legislation. These mean that countries willing to introduce probation and such measures are better advised to develop legislation to support the actions thereafter.
Whereas its easy to replicate social inquires and presentence report writing, it is not the case with use of structured risk assessment tool. The tools need though appreciation of the theoretical foundational and training before application of the given tool. In addition, the tools which may be developed in one jurisdiction should not be translocated and used in another jurisdiction without going through the process of domestication. This is because the tools also take cognizance of cultural differences and as such need be domesticated and made culturally sensitive and relevant to each jurisdiction.
Whichever is the case, there will still be genuine need to train officers working with the court and with the assessment tools so that outcomes are not skewed to render ‘inaccurate’ or biased justice.
Clement Okech
Deputy Director,
Probation and Aftercare Service, Kenya
M.A. Youth Justice, Probation and Applied Criminology
Middlesex University, London
This email address is being protected from spambots. You need JavaScript enabled to view it.
[1] Following Covid 19 pandemic, the Kenyan justice system decongested the prisons through sentence review with most having their prison terms being converted to community service order supervision and probation orders.
[2] World Prison Report Available at https://www.prisonstudies.org/sites/default/files/resources/downloads/world_prison_population_list_13th_edition.pdf accessed on 29th October 2022
[4] Sec 34 of the Judicial Service Act of 2011
[5] Article 159 of the Constitution of Kenya 201
[6] Section 24 of the Penal Code Chapter 63 laws of Kenya and Sentencing Policy Guidelines 2016
[7] Sexual offences Act, Forest Act, Wildlife Conservation Act, and the Alcoholic beverages Act
[8] Nellis, M. (2007, humanizing justice: the English probation service up to 1972, in Gelsthorpe, L. and Morgan, R. (eds) Handbook of Probation, Willan Publishers
[9] Kenya Judiciary: State of Judiciary and the Administration of Justice Report 2018/19: file:///C:/Users/admin/Downloads/SOJAR%20REPORT%202018%20_%202019%20final.pdf access on 29th October 2022
[10] Easton, S. and Piper, C (2008), Sentencing and Punishment, the Quest or Justice, (second Edition), Oxford university Press.
[11] Hedderman, C. (2007), Past Present and future sentences: what do we know about their effectiveness? I Gelsthorpe, L. and Morgan, R. (eds) Handbook of Probation, Willan Publishers
[12] Easton, S. and Piper, C (2008), Sentencing and Punishment, the Quest or Justice, (second Edition), Oxford university Press.
[13] The Judiciary of Kenya: Sentencing Policy Guidelines (2016) available at https://www.judiciary.go.ke/download/sentencing-policy-guidelines/ Accessed on 29th October 2022
[14] Section 4 of the Probation of offenders Act Cap 64 Laws od Kenya
[15] Nash, M. (2003), Pre-trial investigation in Chui, H.W and Nellis, M (eds) Moving Probation Forward, Evidence, Arguments and Practice. Pearson Education
[16] Social Investigations and presentence reports writing guidelines for probation officers, (2016)
[17]The term “sex” (male/ female) is used as a biological term, describing physical attributes and chromosomes that are universal, whereas the term “gender” refers to the roles, behaviours and attributes society attaches to and considers appropriate for men and women.
[18]For further interpretation of Article 30 see General Comment No. 1 of the African Committee of Experts on the Rights and Welfare of the Child. Section 36 states: ‘Implementation of Article 30 requires that States parties review their sentencing procedure and reform it accordingly so that: (a) A sentencing court should find out whether a convicted person is a primary caregiver whenever there are indications that this might be so. (b) The court should also ascertain the effect on the children concerned of a custodial sentence if such a sentence is being considered. (c) If the appropriate sentence is clearly custodial and the convicted person is a primary caregiver, the court must apply its mind to whether it is necessary to take steps to ensure that the children will be adequately cared for while the caregiver is incarcerated. (d) If the appropriate sentence is clearly non-custodial, the court must determine the appropriate sentence, bearing in mind the best interests of the child. (e) Finally, if there is a range of appropriate sentence, then the court must use the principle of the best interests of the child as an important guide in deciding which sentence to impose.’
[19]The Sentencing Policy Guidelines for judges and magistrates were developed by a Task Force appointed in 2014 through Gazette Notice No. 4087 with the mandate to review the past sentencing patterns and policies and recommend how to reduce unwarranted disparity and promote proportionality in passing judgment. The Guidelines were launched by then Hon. Chief Justice, Dr. Willy Mutunga, D.Jur, SC, EGH on 25 January 2016. Available at: www.kenyalaw.org/kl/fileadmin/.../Sentencing_Policy_Guidelines_Booklet.pdf
[20] Hudson, B (2001), ‘Human Rights Public Safety and the Probation Service: Defending Justice in the Risk Society’, Howard Journal of Criminal Justice, 40,103-113.
[21] Easton, S. and Piper, C (2008), Sentencing and Punishment, the Quest or Justice, (second Edition), Oxford university Press.
[22] For detailed discussion, see D.A. Andrews and Bonta, J. (2010) The Psychology of Criminal Conduct, Fifth Edition
[23] Andrews, D. A., & Bonta, J. (1995). LSI-R: The Level of Service Inventory–Revised. Toronto, Ontario, Canada: Multi-Health Systems.
[24] S. 7 of the UN Standard Minimum Rules for the Noncustodial measures, 1990 (TOKYO RULES)