Chowdury v Greece
(2017) ECHR 300
Independent editorial summary — not the official judgment. Read the full judgment via the source link.
Ratio Decidendi
The state has positive obligations under Article 4 ECHR to investigate situations of potential human trafficking and forced labour, even where the victims did not initially raise formal complaints.
Facts
Bangladeshi migrant workers were recruited to work on strawberry farms in Greece under exploitative conditions. They worked excessive hours for little or no pay and were subject to armed supervision.
Judgment Summary
The ECtHR held that Greece violated Article 4, finding that the workers were victims of forced labour and trafficking. The state failed to fulfil its positive obligations to prevent, investigate, and punish trafficking.
Key Quotes
"The state's duty to penalise and prosecute trafficking is not limited to cases where victims formally complain."
— The Court
Subsequent Treatment
Cited in subsequent cases on state positive obligations under Article 4.
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