판결 이유
Article 4 ECHR (prohibition of slavery and forced labour) imposes positive obligations on states to penalise and prosecute effectively any act aimed at maintaining a person in a situation of slavery, servitude, or forced labour.
사실관계
A Togolese girl was brought to France and made to work as an unpaid domestic servant for years. She was confined to the home and had her passport confiscated.
판결 요약
The ECtHR held that France had violated Article 4 by failing to have adequate criminal legislation to protect against servitude and forced labour. The court distinguished between slavery, servitude, and forced labour.
주요 인용문
"Article 4 enshrines one of the basic values of the democratic societies making up the Council of Europe."
— The Court
후속 처리
Led to strengthening of anti-trafficking and modern slavery legislation across Europe, including the UK's Modern Slavery Act 2015.