判决理由
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.
事实
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.
判决摘要
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.
关键引述
"The state's duty to penalise and prosecute trafficking is not limited to cases where victims formally complain."
— The Court
后续处理
Cited in subsequent cases on state positive obligations under Article 4.