“The absence of an express reference to trafficking in the [European] Convention [on Human Rights] is unsurprising. The Convention was inspired by the Universal Declaration of Human Rights, proclaimed by the General Assembly of the United Nations in 1948, which itself made no express mention of trafficking. In its Article 4, the Declaration prohibited ‘slavery and the slave trade in all their forms’. However, in assessing the scope of Article 4[1] of the Convention, sight should not be lost of the Convention’s special features or of the fact that it is a living instrument which must be interpreted in the light of present-day conditions. The increasingly high standards required in the area of the protection of human rights and fundamental liberties correspondingly and inevitably require greater firmness in assessing breaches of the fundamental values of democratic societies (…). The [European] Court [of Human Rights] notes that trafficking in human beings as a global phenomenon has increased significantly in recent years (…). In Europe, its growth has been facilitated in part by the collapse of former Communist blocs. The conclusion of the Palermo Protocol in 2000 and the Anti-Trafficking Convention in 2005 demonstrate the increasing recognition at international level of the prevalence of trafficking and the need for measures to combat it.” (Rantsev v. Cyprus and Russia, judgment of 7 January 2010, §§ 277-278).

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