EUROPEAN COURT OF HUMAN RIGHTS: RANTSEV V. CYPRUS & RUSSIA

摘要

In a unanimous judgment, the European Court of Human Rights has ruled that human trafficking violates Article 4 (prohibition of slavery, servitude and forced labor) of the European Convention on Human Rights. The case was brought by the father of a 20-year-old Russian woman who was found dead soon after she arrived in Cyprus on an "artiste" visa. In its judgment, the Court set out the positive obligations owed by states of origin, transit, and destination under Article 4 with respect to trafficking. It found Cyprus in violation of Article 4 in failing to protect the victim from being trafficked and failing to adequately investigate her death, Article 2 (right to life) in failing to conduct an effective investigation of her death, and Article 5 (arbitrary detention). The Court also found that Russia violated Article 4 in failing to effectively investigate how and where she had been trafficked, and who was involved in recruiting her.