C.N. and V. v. France  |2012

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

It’s ok now. I have a job, a husband, two children, a house… I’m 34 years old, I’m starting to live.

C.N., quoted in Le Monde (in French)


Two sisters, C.N. and V., were orphaned when their parents were killed during the civil war in Burundi in the early 1990s. Their family decided that the girls should go and live with their aunt and uncle, Mr. and Mrs. M., near Paris.

When the sisters arrived in France, Mr. and Mrs. M. housed them in a cold cellar and made them do housework, with no pay or time off. The youngest girl, V., went to school, but her aunt refused to pay for her lunch and bus fare.

Social services were made aware of the situation, and, in 1995, the police were told that the girls were possibly being exploited. Nothing came of the report.

Several years passed before prosecutors launched a criminal investigation after a children’s rights charity made a complaint.

In 2007, a French court found Mr. and Mrs. M. guilty of abusing C.N. and V.’s vulnerability by making them live and work in poor conditions. Mrs. M. was also convicted of assaulting V.

However, after the couple appealed, a higher court cleared them of the first charge and upheld only the assault charge against Mrs. M.

Judgment of the European Court of Human Rights

The European court found that, in particular, C.N., the older of the two girls, was kept as a servant and made to do forced labour, in violation of her human rights. V.’s circumstances were different and did not amount to servitude and forced labour.

French law at the time did not properly protect C.N. from exploitation. The European court relied on its previous findings in a 2005 judgment against France in the case of Henriette Siliadin, who was also a foreign victim of forced labour in the 1990s.

The court ordered France to pay C.N. €30,000 in damages.

...the Court considers that [C.N.] was forced to work so hard that without her aid Mr. and Mrs. M. would have had to employ and pay a professional housemaid.

Judgment of the European Court of Human Rights, October 2012


Henriette Siliadin’s case had already prompted France to improve legal protections for victims of servitude, forced labour, and human trafficking.

But the European court’s judgment in C.N. and V.’s case partly inspired the French authorities to go further. In 2013 a new law was introduced, changing the Criminal Code to better define and combat human trafficking.