The Weekly Round Up: Human trafficking, modern slavery and the Troubles legacy case
10 May 2026
In the news
On Tuesday, the Council of Europe’s group of experts on action against trafficking in human beings (GRETA) published an evaluation report, raising concerns about barriers to victims accessing legal assistance and free legal aid in the UK [208-217].
The report noted that the Government had failed to provide legal assistance during the identification process and prior to entering the NRM, and to ensure that free legal aid is available for the procedure before the Criminal Injuries Compensation Schemes — despite the fact that these recommendations had been “made repeatedly” by GRETA in previous reports [287].
GRETA also warned that victims of trafficking continue to be prosecuted and convicted for offences that they were compelled to commit as part of their exploitation, despite the revised guidance on the non-prosecution of victims of human trafficking [236-253] — produced in response to the V.C.L. and A.N. v the United Kingdom (App nos 77587/12 and 74603/12) [2021] ECHR. In that case, the European Court of Human Rights held that the UK had breached the rights to freedom from slavery and to a fair trial, as guaranteed by Articles 4 and 6 of the European Convention on Human Rights, by prosecuting two potential victims of child trafficking.
GRETA recommends providing further training and guidance to law enforcement officers and legal professionals on the application of the non-punishment provision in order to “address the subtle ways by which victims can be compelled to commit offences” [253].
The publication of the report comes on the same day as the Independent Anti-Slavery Commissioner, Eleanor Lyons, warned that the Government’s current response to modern slavery is “no longer sufficient”.
According to the Commissioner’s report, referrals into the National Referral Mechanism (NRM) reached 23,411 in 2025 — the highest number on record and a 22% increase from 2024. The report also highlights a 54% rise in the sexual exploitation of British girls in the last five years, with children accounting for almost a third of NRM referrals in 2025.
The report warned that technology — including AI, cryptocurrencies, and online platforms — is accelerating and obscuring exploitation.
The Anticipating Exploitation: A Futures Analysis report also raised concerns that the conflation of immigration and modern slavery risks a lack of coherence and “oversimplifying the problem”. The report notes that British nationals are now the highest proportion of victims of modern slavery, with one in five individuals referred to the NRM last year being a UK national.
In other news:
- Two Sudanese asylum seekers have launched the first legal challenge against the new Home Office policy of granting only temporary status to refugees, on the basis that it is discriminatory and an ineffective deterrent to asylum seekers, according to a report published this week by The Guardian.
- The Secretary General of the Council of Europe, Alain Berset, told Politico that a “consequence” of the UK leaving the European Convention on Human Rights would be that it would “create a new group” of countries, with Russia and Belarus.
- On Monday, Meta filed a request to overturn a landmark ruling by the California Superior Court, which found Meta and Google liable for the deterioration of a young woman’s mental health by designing addictive products.
In the courts
Dillon v Secretary of State for Northern Ireland [2026] UKSC 15
On Thursday, the Supreme Court unanimously allowed the Government’s appeal, holding that the Northern Ireland (Legacy and Reconciliation) Act 2023 (“the 2023 Act”) did not result in a diminution of rights contrary to Article 2(1) of the Windsor Framework, which forms part of the EU-UK Withdrawal Agreement.
The case stemmed from judicial review proceedings brought by four Troubles victims — Martina Dillon, John McEvoy, Brigid Hughes and Lynda McManus — who challenged the provisions of the 2023 Act relating to the granting of immunity and the termination of police investigations into Troubles-related offences [14]. Around 1,200 cases relating to killings during the Troubles remain unsolved [1].
Article 2(1) of the Windsor Framework provides that the United Kingdom “shall ensure that no diminution of rights, safeguards or equality of opportunity, as set out in that part of the [Belfast] Agreement” results from its withdrawal from the EU [69].
The Court held that the 2023 Act did not diminish the rights conferred by the EU Victims Directive, and therefore did not give rise to a diminution of rights results from withdrawal from the EU. The Court emphasised that the Victims Directive is “not the source of a right for all victims of crime to see perpetrators prosecuted” [137].
The Court — following the judgments in Case 12/86 Demirel v Stadt Schwabisch Gmund [1987] ECR 3719 and Case C-240/09 Lesoochranárske zoskupenie VLK v Ministerstvo životného prostredia Slovenskej republiky [2012] — upheld that Article 2(1) is capable of having direct effect if, regard being had to its wording, purpose and nature, it contains a clear and precise obligation that does not depend on further action by the EU or the UK before it can take effect [112].
However, in the present case the specific provisions relied upon in the Belfast Agreement cannot have direct effect because they are expressed in too general terms, including “civil rights”, “mutual respect”, “religious liberties”, “acknowledge and address the suffering of the victims of violence” and “a right to remember” [114].
The judgment follows a House of Commons carry-over motion on the Northern Ireland Troubles Bill, passed the previous week, which seeks to repeal and replace the 2023 Act.
On the UKHRB
- Dan Pollen examines freedom of expression in the context of secondary education.
