Institute for Migrant Rights
Railway line at Cianjur station, c. 1890 · KITLV, CC BY 4.0

Migration Jurisprudence from the South › United Kingdom

V.C.L. and A.N. v. the United Kingdom

European Court of Human Rights · United Kingdom · 2021-02-16 · Regional court or body

Citation: App. nos. 77587/12 and 74603/12
Type of case: Constitutional and human rights
Outcome: Decided for the migrant side

Question

May trafficked children forced to work on cannabis farms be prosecuted for drug offences?

What the court decided

No, not without first assessing whether they were trafficked. Prosecuting them breached Article 4 and the fairness of the trial under Article 6.

In plain language

Two Vietnamese teenagers found working on cannabis farms in England were prosecuted instead of being treated as trafficking victims. The Court said this broke the Convention.

Dalam bahasa sederhana

Dua remaja Vietnam yang ditemukan bekerja di ladang ganja di Inggris dituntut alih-alih diperlakukan sebagai korban perdagangan orang. Mahkamah menyatakan ini melanggar Konvensi.

Pertanyaan: Bolehkah anak korban perdagangan yang dipaksa bekerja di ladang ganja dituntut atas kejahatan narkotika?

What happened afterwards

  • 2021-02-16: Judgment.

Sources

Open this decision in the interactive collection (compare, filter, Indonesian view, downloads).

Cite as: Institute for Migrant Rights (2026), Migration Jurisprudence from the South, version 0.1, https://theimr.org/court-decisions/d/echr-vcl-2021/. This page summarizes a court decision for research and advocacy; it is not legal advice.

For researchers

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Keywords: case law; jurisprudence; judicial decisions; comparative constitutional law; courts and migration; judicial behavior; litigation outcomes; refugee law; non-refoulement; citizenship and nationality; empirical legal studies; empirical legal scholarship; quantitative legal research; statistical analysis in law; law and economics; law and economics of migration; comparative law; socio-legal studies; legal pluralism; migration law; labor migration; migrant workers’ rights; human rights law; access to justice; Global South; Asia; Africa; Middle East; Latin America; Indonesia; open data; replication data.