… protection of domestic employees: states must take the necessary measures to protect individuals against domestic slavery.

In 2005, the Court found that there had been a violation of Article 4 in the Siliadin v. France case. Siwa-Akofa Siliadin complained that French criminal law had not afforded her sufficient and effective protection against the “servitude” in which she had been held, or at the very least against the “forced and compulsory” labour she had been required to perform, which in practice had made her a domestic slave. The Court considered that the French criminal legislation in force at the relevant time had not afforded the applicant specific and effective protection against the actions of which she had been a victim.

… action against human trafficking

In January 2010, the Court found that there had been a violation of Article 4 in the Ranstsev v. Cyprus and Russia case, holding that the Cypriot and Russian authorities had failed to protect a 20-year old Russian cabaret artist from human trafficking.  This was the Court’s first judgment regarding trafficking in human beings.