Case No. UKUT-00226-(IAC)

[2013] EWCA Crim 324 is especially notable for the following observations of the Lord Chief Justice on what he described as “ the troublesome crime of exploitation of labour ”, at [5]: “The problem has been with us for some time, and has been growing. Unhappily different forms of exploitation are found in the sex industry, the construction industry, agriculture and residential care. That list is not comprehensive. Those who are exploited are always and inevitably vulnerable, and just because they are so vulnerable, profoundly reluctant to report what has happened or is happening to them. The Asylum and Immigration Act 2004 criminalised the exploitation of labour when it was connected to trafficking in human beings, but not otherwise. Therefore it did not prevent vulnerable but untrafficked individuals from being subjected to forced or compulsory labour. The Gang Masters ' Licensing Act 2004 established a system for licensing those who employed workers in specified industries. Nevertheless, this legislation, too did not address the entire problem. The end result was that many men and women continued to remain vulnerable to exploitation without any counter-balancing protection against exploitation. ” Having noted the reform effected by section 71 of the Coroners and Justice Act 2009, the Court drew particular attention to the decision of the ECTHR in Si li