highlighted among the "basic principles" underwriting the draft codifying instrument. However, States would fail to comply with the full scope of their obligations to protect migrants in administrative detention if their sole actions are to refrain from arbitrarily detaining and/or subjecting persons to torture or ill-treatment. Equally fundamental in this context are the right of every person to basic dignity and humanity, as well as the heightened duties of safety and care to which individuals in particularly vulnerable situations are entitled. In order to uphold migrants’ dignity and humanity, additional legal safeguards are also critical, such as access to a lawyer from the outset of the migration procedure, the right to appeal or review the detention order, the assistance of an interpreter and to have information provided in a language the migrant understands. These additional rights should be further promoted and reinforced within the draft codifying instrument. Doing so will help to re-frame the exercise from one in which standards are put in place to merely avoid serious harms or abuses; to one that provides guidance to States on how to properly ensure the safety, dignity and humanity of all migrants within places of administrative immigration detention. 3. Clarify that administrative immigration detention is never acceptable for migrants in situations of particular vulnerability Migrants in situations of particular vulnerability should never be detained for reasons of administrative immigration enforcement. Such detention is not necessary, poses serious risks of torture and ill-treatment, and is inconsistent with international legal obligations prohibiting arbitrary detention. The current draft codifying instrument implicitly condones the immigration detention of a range of migrants in situations of particular vulnerability including migrant children, families, pregnant women and nursing mothers, persons with disabilities, elderly persons, stateless persons, asylum seekers, persons discriminated against on the grounds of their sexual orientation and gender identity, and victims of trafficking, torture, trauma or other abuse. Detention merely for the purposes of administrative immigration enforcement is never a measure that can appropriately protect these individuals from serious harms of torture or ill-treatment, and will often be arbitrary given the abundance of alternative measures to detention. Rather than adopting rules for the detention of persons in situations of vulnerability, the CDCJ should insist on their referral to protection systems and on their accommodation in care and protection-based alternatives to detention. Additionally, the CDCJ should encourage States to assess such situations of vulnerability prior to ordering detention, so that their detention can be avoided. Finally, the CDCJ should insist more strongly that States have an obligation to monitor the evolution of vulnerability factors within detention so that persons identified as being in situations of vulnerability can be immediately released. 4. Call for the priority application of alternative measures to detention A critical safeguard for avoiding arbitrary detention in the context of administrative immigration enforcement is the robust application of alternative measures to detention. Like the right to procedural safeguards or the requirement that detention have a legitimate purpose, the obligation to pursue alternative measures to detention is a critical component of non-arbitrariness. Any detention must be strictly necessary and 3