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England and Wales decisions
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Assessment of damages in a modern slavery claim, with a composite award for false imprisonment and injury to feelings, plus separate awards for psychiatric injury, unpaid wages and exemplary damages.
COL v The United Arab Emirates [2026] EWHC 86 (KB) (22 January 2026)
The High Court assessed damages for a modern slavery claim, awarding sums for false imprisonment, psychiatric injury, exemplary damages, unpaid wages, and treatment costs.
The conviction on count 1 was unsafe due to misdirection on servitude, lack of evidence for servitude, and inadequate direction on slavery; section 1(1)(a) creates a single offence; jury may have convicted on an improper basis; convictions on count 1 quashed; sentences for remaining offences not manifestly excessive.
Source excerpt
Webb & Anor v R [2025] EWCA Crim 1491 (19 November 2025)
The Court of Appeal quashed convictions for holding a vulnerable man in slavery or servitude, finding errors in the jury directions. Sentence appeals on other counts failed.
R v BXR [2022] EWCA Crim 1483 (10 November 2022)
The Court of Appeal quashed BXR’s convictions after finding his offending was closely linked to trafficking-related compulsion and prosecution would likely not have been in the public interest.
The Supreme Court held that a diplomat’s exploitation of a domestic worker in modern slavery can be a commercial activity, defeating immunity under Article 31(1)(c).
The Court of Appeal rejected claims that a juror’s complaint of prejudice required discharge of the jury, holding the trial judge’s directions cured any risk.
The Court of Appeal quashed SK’s conviction for trafficking for exploitation, holding that the jury directions failed to properly explain Article 4 concepts and overstressed pay and hours.
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