CCPR/C/GC/35 may, in appropriate circumstances, be limited to review of the reasonableness of a prior determination.125 40. The right applies to all detention by official action or pursuant to official authorization, including detention in connection with criminal proceedings, military detention, security detention, counter-terrorism detention, involuntary hospitalization, immigration detention, detention for extradition and wholly groundless arrests. 126 It also applies to detention for vagrancy or drug addiction, detention for educational purposes of children in conflict with the law127 and other forms of administrative detention. 128 Detention within the meaning of paragraph 4 also includes house arrest and solitary confinement.129 When a prisoner is serving the minimum duration of a prison sentence as decided by a court of law after a conviction, either as a sentence for a fixed period of time or as the fixed portion of a potentially longer sentence, paragraph 4 does not require subsequent review of the detention.130 41. The object of the right is release (either unconditional or conditional)131 from ongoing unlawful detention; compensation for unlawful detention that has already ended is addressed in paragraph 5. Paragraph 4 requires that the reviewing court must have the power to order release from the unlawful detention. 132 When a judicial order of release under paragraph 4 becomes operative (exécutoire), it must be complied with immediately, and continued detention would be arbitrary in violation of article 9, paragraph 1.133 42. The right to bring proceedings applies in principle from the moment of arrest and any substantial waiting period before a detainee can bring a first challenge to detention is impermissible.134 In general, the detainee has the right to appear in person before the court, especially where such presence would serve the inquiry into the lawfulness of detention or where questions regarding ill-treatment of the detainee arise.135 The court must have the power to order the detainee brought before it, regardless of whether the detainee has asked to appear. 43. Unlawful detention includes detention that was lawful at its inception but has become unlawful because the individual has completed serving a sentence of imprisonment or the circumstances that justify the detention have changed. 136 After a court has held that the circumstances justify the detention, an appropriate period of time may pass, depending 125 126 127 128 129 130 131 132 133 134 135 136 1051/2002, Ahani v. Canada, para. 10.2; 754/1997, A. v. New Zealand, para. 7.3. 248/1987, Campbell v. Jamaica, para. 6.4; 962/2001, Mulezi v. Democratic Republic of the Congo, para. 5.2; 1051/2002, Ahani v. Canada, para. 10.2; 1061/2002, Fijalkowska v. Poland, para. 8.4; 291/1988, Torres v. Finland, para. 7.4; 414/1990, Mika Miha v. Equatorial Guinea, para. 6.5. 265/1987, Vuolanne v. Finland, para. 9.5; see concluding observations: Rwanda (CCPR/C/RWA/CO/3, 2009), para. 16 (recommending abolition of detention for vagrancy). See concluding observations: Republic of Moldova (CCPR/CO/75/MDA, 2002), para. 11. 1172/2003, Madani v. Algeria, para. 8.5; 265/1987, Vuolanne v. Finland, para. 9.5. 954/2000, Minogue v. Australia, para. 6.4; 1342/2005, Gavrilin v. Belarus, para. 7.4. Article 14, paragraph 5, however, guarantees criminal defendants the right to a single appeal from an initial conviction to a higher court (general comment No. 32, para. 45). 473/1991, Barroso v. Panama, paras. 2.4 and 8.2 (habeas corpus for bail). 1324/2004, Shafiq v. Australia, para. 7.4. 856/1999, Chambala v. Zambia, para. 7.2. 291/1988, Torres v. Finland, para. 7.2 (seven days). See Body of Principles (note 102 above), principle 32, para. 2; general comment No. 29, para. 16. 1090/2002, Rameka v. New Zealand, paras. 7.3–7.4. 13