Background
LR, an Albanian national born in 2005, left Albania with his abusive father at age 16 and later escaped from him in Belgium. Albanian men who had befriended LR then forced him to work without pay in a warehouse and arranged to sell him to another group for exploitation in cannabis cultivation in the United Kingdom. LR escaped en route, entered the United Kingdom in January 2022 and disclosed his experiences to police. The Home Secretary accepted that he had experienced domestic violence and trafficking but refused his protection claim, reasoning that Albania could provide sufficient protection.
The First-tier Tribunal dismissed LR’s appeal on international-protection grounds despite accepting that his traffickers had threatened him through his mother and might pursue him in Albania. It allowed his appeal under Article 8 of the European Convention on Human Rights because his vulnerabilities would create very significant obstacles to reintegration. The Upper Tribunal later set aside the protection decision for legal error and selected the case to provide country guidance concerning Albanian male victims of trafficking.
The Court’s Holding
The Upper Tribunal allowed LR’s appeal on international-protection grounds. It also held that Albanian male victims of trafficking constitute a particular social group, both before and after the Nationality and Borders Act 2022, because they share a common background and are perceived as distinct by Albanian society. Refugee status nevertheless requires a causal connection between feared persecution and membership of that group.
The Tribunal found a general sufficiency of state protection for adult male trafficking victims in Albania, but stressed that protection will not be effective in every case. Risk must be assessed individually by considering the victim’s vulnerabilities, the traffickers’ organisation, reach and continuing interest, prior threats, family or community connections, available evidence against the traffickers and the passage of time. Albania has no shelter accommodation for individual adult male victims; NGO-supported rented accommodation and reintegration assistance may suffice in many cases, but not necessarily for a person who needs shelter to remain safe.
Internal relocation likewise requires an individual assessment. It will generally not be unduly harsh for adult male victims who face no risk of reprisal or re-trafficking. A person who needs shelter to be safe in his home area, however, is unlikely to be safe elsewhere, while someone still sought by traffickers is unlikely to be safe outside Albania’s larger cities. Safety within a larger city depends on the traffickers’ reach and intent, their official connections and the victim’s vulnerabilities and ability to obtain rehabilitation and support.
Key Takeaways
- There is no single profile of an Albanian male trafficking victim; relevant risk factors include youth, poverty, limited education, poor health, rural or northern origin, lack of support, adverse childhood experiences, minority ethnicity and LGBT identity.
- Past trafficking or threatened persecution is a serious indication of future risk unless there are good reasons to conclude that it will not recur, but the risk of re-trafficking cannot be quantified generically.
- Albania generally provides sufficient protection, yet the absence of dedicated shelter for individual adult men and practical barriers to reintegration may be decisive in a particular case.
Why It Matters
This decision supplies authoritative country guidance for the significant number of United Kingdom asylum appeals involving Albanian men trafficked into forced labour or criminal exploitation. It rejects categorical outcomes in either direction: neither past trafficking nor Albania’s formal protection system determines the claim without close attention to the individual victim, the traffickers and the support realistically accessible on return.