Siliadin v. France  | 2005

Human trafficking criminalised after 14-year-old girl kept in domestic servitude in Paris

I was a slave . . . I knew that what was happening to me was unfair because I had a family before and knew how human beings should be treated.

Henriette Akofa Siliadin, interview with Human Rights Europe - © Photo: Council of Europe



Henriette Akofa Siliadin arrived in France from Togo when she was 14 years old. She was vulnerable and dependent on others. However, the people accompanying her took away her passport and made her work as an unpaid servant, all day long, 7 days a week for over four years. When the authorities intervened, she had to stay in hospital for six months to recover.

Legal proceedings followed her release, which allowed Henriette to be awarded unpaid wages. However, the people responsible were never convicted of a crime in the French courts.

Judgment of the European Court of Human Rights

The European court found that, according to French law at the time, keeping a person in domestic servitude or slavery was not explicitly outlawed. Therefore, the law had not properly protected Henriette or criminalised the actions of her captors – in violation of her basic rights.


After these events, servitude, forced labour and slavery all became criminal offences in France. The judgment of the European court led to further changes in the legislation in order to properly protect people in similar situations. Human trafficking was criminalised in France in 2007.

In 2008 France ratified the Council of Europe’s Convention on Action against Trafficking in Human Beings.


Related examples

Justice for an orphan whose aunt and uncle kept her as a servant

C.N. and her sister V. were sent to live with their aunt and uncle in France after their parents died. They were put to work and made to sleep in a cold cellar. The European court found that, in particular, C.N.’s circumstances amounted to servitude and forced labour. After the European court’s judgment, France passed a new law to better define and combat human trafficking.

Read more

Justice for mentally handicapped sixteen-year old subjected to sexual abuse

Mentally handicapped Miss Y. was sexually abused the night after her sixteenth birthday. Y.’s father tried to bring a criminal prosecution against the attacker, but Dutch law stated that only the victim could start such a prosecution. Y.’s condition meant she could not do this, so her attacker was not brought to justice. The European court ruled that this violated her basic rights.

Read more

Failure to investigate alleged brutality against man trying to help the police

Cvetan Trajkoski tried to report a dangerous situation to the police. He was then allegedly beaten by a group of officers – apparently because he had parked his car in the wrong place. The European court ruled that the authorities had failed to properly investigate the alleged attack. This and other cases led to reforms to ensure proper investigations of alleged police brutality.

Read more