In May 2003, a Roma family with Bulgarian nationality traveled to Italy with a promise of work in a villa. M.’s parents alleged that they were threatened and forced to return to Bulgaria, leaving M.—their 17 year old daughter—in the villa, where she was raped and beaten. M.’s mother returned to Italy on 24 May and reported to the police that her daughter had been kidnapped. M. was rescued from the villa seventeen days later, on 11 June 2003. No criminal proceedings were taken against M.’s kidnapper but the police instituted proceedings against M.’s parents for perjury and libel, believing that the accusations of kidnapping were untrue and that M.’s parents had contracted to marry M. to the alleged kidnapper for a sum of money. The European Court of Human Rights found a violation of Article 3—prohibition of ill-treatment—in the investigation of rape and beating by the Italian authorities, which it ruled was ineffective. The Court found no violation of Article 3, however, in the steps taken by the police to secure the release of M.
M. and Others v. Italy and Bulgaria