F.M. AND OTHERS v. RUSSIA - 71671/16 (Article 4 - Prohibition of slavery and forced labour : Third Section) [2024] ECHR 895 (10 December 2024)

F.M. AND OTHERS v. RUSSIA - 71671/16 (Article 4 - Prohibition of slavery and forced labour : Third Section) [2024] ECHR 895 (10 December 2024)

The Court found that Russia failed to fulfil its substantive and procedural positive obligations under Article 4 to protect the applicants from trafficking and labour exploitation, failed to provide an adequate legislative and administrative framework, did not identify or assist the victims, failed to investigate...

Source-derived case information.

Citation
[2024] ECHR 895
Parties
Applicants: F. M. and Others; Respondent: Russian Federation
Jurisdiction
European Union
Judgment Date
10 December 2024
Procedural Posture
Application to the European Court of Human Rights / Judgment
Outcome
Violation of Article 4 and Article 14 (in conjunction with Article 4) of the Convention found against Russia.
Legal Topics
Human Trafficking, Forced Labour, Servitude, State Positive Obligations, Discrimination Against Migrant Workers, Gender Based Violence, Failure to Investigate, Cross Border Cooperation
Human Rights Law Labour Law Criminal Law Anti Trafficking Law Human Trafficking Forced Labour Servitude State Positive Obligations +4 more

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Parties

F. M. and Others

Applicants

Russian Federation

Respondent

Procedural Posture

Application to the European Court of Human Rights / Judgment

Legal Issues

  1. 1 Whether Russia failed to fulfil its positive obligations under Article 4 of the Convention to protect female migrant workers from trafficking and labour exploitation
  2. 2 Whether there was a failure to investigate credible allegations of trafficking, forced labour, servitude, and gender-based violence
  3. 3 Whether the authorities' inaction reflected discrimination under Article 14 in conjunction with Article 4

Ratio Decidendi

The Court found that Russia failed to fulfil its substantive and procedural positive obligations under Article 4 to protect the applicants from trafficking and labour exploitation, failed to provide an adequate legislative and administrative framework, did not identify or assist the victims, failed to investigate credible allegations, and exhibited a discriminatory attitude towards irregular female migrant workers, violating Article 4 and Article 14 in conjunction with Article 4.

Court Disposition

Violation of Article 4 and Article 14 (in conjunction with Article 4) of the Convention found against Russia.

Orders

  • Respondent State to take measures to prevent similar violations in the future
  • Respondent State to provide appropriate redress to the applicants, including compensation for damages suffered