Case Law On Human Trafficking Suppression Act Enforcement And Notable Convictions

11 Oct 2025 --
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1. Attorney-General v. Anas Aremeyaw Anas & Others (Ghana, 2016)

Facts:

Under the Human Trafficking Act, 2005 (Act 694) of Ghana, several individuals were arrested for operating a trafficking ring that transported children from northern Ghana to the coastal areas for forced labor in fishing communities. Investigative journalist Anas Aremeyaw Anas’s undercover documentary provided crucial evidence of the traffickers’ operations.

Legal Issues:

The main issue was whether the video evidence and testimonies sufficiently proved that the victims were recruited and transported for exploitation under the Human Trafficking Act.

Judgment:

The court upheld the convictions, ruling that the elements of trafficking were fully established — recruitment, transportation, deception, and exploitation.
The traffickers were sentenced to 10–15 years imprisonment, and the court ordered restitution for the victims.

Significance:

This case set a precedent for the admissibility of undercover evidence in trafficking prosecutions. It also reinforced the duty of the state to provide protection and rehabilitation to rescued victims under the Act.

2. Republic v. Ijeoma Eze (Kenya, 2019)

Facts:

A Nigerian national, Ijeoma Eze, was accused of trafficking several young women from Kenya and Uganda to the Middle East with promises of domestic jobs, only for them to be subjected to forced labor and sexual exploitation.

Legal Provisions:

Charged under the Counter-Trafficking in Persons Act, 2010 (Kenya), sections dealing with trafficking by deception, confiscation of travel documents, and organized criminal group participation.

Judgment:

The court found Eze guilty on multiple counts and sentenced her to 20 years imprisonment.
The court observed that confiscating victims’ passports and restricting communication were clear indicators of coercion and exploitation.

Significance:

It clarified that trafficking can occur even with the victim’s initial consent if deception or coercion is involved.

Strengthened Kenya’s stance on international cooperation against trafficking syndicates operating across borders.

3. Federal Republic of Nigeria v. Ugochukwu Emmanuel (Nigeria, 2020)

Facts:

Ugochukwu Emmanuel, a travel agent, was charged under the Trafficking in Persons (Prohibition) Enforcement and Administration Act, 2015 for organizing the transportation of girls to Europe for sexual exploitation.

Legal Issues:

The defense argued that the victims had consented and paid for the trip themselves.
The prosecution argued that the victims were deceived regarding the nature of the work.

Court’s Decision:

The Federal High Court convicted the accused, holding that consent is immaterial when obtained through deceit or abuse of vulnerability. Emmanuel received a 7-year prison sentence and was ordered to pay compensation to the victims.

Significance:

This case strengthened the principle that “informed consent” cannot exist under deception.

It also emphasized victim protection and restitution, as directed under the Act’s victim-centered approach.

4. R. v. Connors & Others (United Kingdom, 2012)

Facts:

In this case, the defendants were part of a family who lured homeless and vulnerable men into forced labor under degrading conditions in the UK. Victims were made to work long hours with no pay and were physically abused.

Charges:

Brought under the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act and Modern Slavery Act 2015 (UK).

Judgment:

The court found the defendants guilty of trafficking for forced labor and imposed prison sentences ranging from 6 to 11 years.

Significance:

The court reaffirmed that human trafficking includes internal/domestic trafficking, not just cross-border cases.

It emphasized coercive control and exploitation, even when physical movement is minimal.

5. Public Prosecutor v. Khong Kok Seng & Others (Malaysia, 2017)

Facts:

Several factory owners were charged with trafficking foreign workers from Bangladesh and Nepal for forced labor. The workers’ passports were confiscated, and they were subjected to inhumane working and living conditions.

Legal Framework:

The Anti-Trafficking in Persons and Anti-Smuggling of Migrants Act 2007 (Malaysia) was invoked.

Judgment:

The High Court found the employers guilty, holding that economic coercion and restriction of freedom constituted trafficking.
Sentences ranged from 8 to 15 years imprisonment, along with fines and forfeiture of business licenses.

Significance:

The case broadened the definition of “exploitation” to include abusive labor practices and debt bondage.

It demonstrated Malaysia’s growing judicial recognition of corporate and employer liability in trafficking crimes.

6. The Queen v. Wei Tang (Australia, 2008)

Facts:

Wei Tang, a Melbourne brothel owner, was charged with possessing and using five Thai women as sex slaves. The women had been brought to Australia with debts and forced to work under exploitative conditions.

Legal Basis:

Charged under the Criminal Code Act 1995 (Cth) — slavery and human trafficking provisions.

Judgment:

The High Court upheld Tang’s conviction, finding that the women were in a condition of slavery even without physical restraints, as they were deprived of freedom and autonomy through threats and debt bondage.