L.E. v. Greece  | 2016

Practical reforms to combat human trafficking

As regards human trafficking in particular, there is a need to adopt a comprehensive approach to combat this phenomenon by putting in place additional measures aimed at punishing traffickers, preventing trafficking, and protecting victims.

Judgment of the European Court of Human Rights, January 2016


When L.E. was 22 she was tricked into travelling to Greece with a human trafficker. When they arrived, the trafficker took away her passport and L.E. was made to work as a prostitute for two years. She was repeatedly prosecuted for breaking prostitution laws and was eventually detained awaiting expulsion. The authorities were then told that she had been the victim of human trafficking.

An investigation began and L.E.’s expulsion was suspended. However, there were significant delays before the prosecutors formally recognised L.E. as being a victim of human trafficking, which meant that she was denied certain protections for nine months.

The prosecutor also failed to start criminal proceedings against the suspected trafficker for five months, despite the authorities having the relevant evidence. After the investigation was started, there were significant shortcomings and delays. Apart from entering the suspect’s name on a register, the police took no real steps to find him and bring him to justice.

Judgment of the European Court of Human Rights

The European court ruled that Greek law at the time had been strong enough to protect L.E. as a victim of human trafficking. However, a series of shortcomings and delays meant that the authorities’ response had fallen short of the standards required by the convention to combat human trafficking – breaching L.E.’s basic rights.


After these events, the Greek authorities introduced a series of new laws and practices to tackle human trafficking as well as a new national rapporteur to supervise and co-ordinate the system for identifying victims.

The court’s judgment was also sent to government agencies, to help make sure that relevant authorities act quickly and diligently in future cases. A special unit of the Greek police has been assigned to address human trafficking, made up of fourteen squads operating across the country.

The Council of Europe’s Committee of Ministers continues to monitor the Greek authorities’ response to human trafficking. Greece is also monitored by the Council of Europe’s Group of Experts on Action against Trafficking in Human Beings (GRETA).