Keywords: Forced Labor; Human Trafficking; Positive Obligations; Gangmaster; Art. 4 ECHR; Modern Slavery.
On 30th March 2017, the European Court of Human Rights (Court) delivered its judgement in the case "Chowdury and others v. Greece" for the violation of Art. 4 of the European Convention on Human Rights (ECHR) in relation to the exploitation of agricultural workers as strawberry pickers, for the first time dealing with the issue of forced labor in agriculture. However, following its previous case-law, the Court linked the violation to human trafficking. While there are some positive steps ahead in defining the notion of forced labor, the overlap with the notion of human trafficking may have an impact on the evaluation of the positive obligations upon States and may exclude most of the victims, i.e. non-trafficked people, from the scope of application of art. 4 ECHR.