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© Copyright, Criminal Cases Review Commission 2026.

Mr IB

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Mr IB left his native Albania in 2016 aged 14 and entered England illegally. He presented himself to police in December 2017 and was placed in foster care. A referral was made to the National Referral Mechanism (NRM), a framework for identifying and supporting trafficking and slavery victims.

In January 2018, Mr IB left foster care and was taken to a car wash in Birmingham and introduced to Albanian men for whom he agreed to drive a car. The next month, the NRM made a ‘reasonable grounds decision’ that Mr IB was the victim of modern slavery.

In May 2021, Mr IB was stopped by police whilst driving a car with a male passenger. He was asked for his licence and insurance but told them he had neither. A search of the vehicle found bags of cocaine and both men were arrested.

Although Social Services were in possession of evidence that Mr IB was at risk of criminal exploitation, no check was carried out of the systems that would have revealed that this was an issue to be considered.

The possibility of modern slavery and human trafficking were also not raised by Mr IB’s solicitor and therefore it was not considered at any stage in the proceedings. At no point was Mr IB advised that he may have had a defence under Section 45 of the Modern Slavery Act 2015.

Mr IB pleaded guilty to the driving offences at the magistrates’ court and was fined £125 and disqualified from driving for three months. No further action was taken regarding the drugs.

In August 2022, the NRM reopened Mr IB’s trafficking file following representations from his solicitors and in February 2023 it made a ‘conclusive grounds decision’ that he was the victim of trafficking or modern slavery.

Mr IB had no right to appeal his conviction directly, due to his guilty plea in the magistrates’ court, but he applied to the CCRC in November 2023. A detailed review of his case found a real possibility that, on any rehearing in the Crown Court, a Section 45 defence would succeed, and the Court would not uphold the conviction.

The CCRC referred the conviction in May 2026.