**Content:**

The Court of Appeal has ruled that being kidnapped for ransom can count as exploitation under human trafficking law, dismissing an appeal by the Home Secretary.

On 4 November 2026, three judges dismissed the Home Secretary's appeal in R (AAM) v Secretary of State for the Home Department [2026] EWCA Civ 1411. Lord Justice Lewis gave the judgment, with two other judges agreeing.

The court held that kidnapping a person and using force or threats to make them get others to pay a ransom "may, depending on the facts, be exploitation" under the trafficking definition.

The case of AAM

The claimant, identified only as AAM, is a Syrian national who was abducted on the road between Benghazi and Tripoli in Libya in 2021. He was beaten, made to telephone his family for money, and held for about a month.

He crossed the Channel by small boat on 16 May 2022 and claimed asylum the next day. The Home Office refused to accept that there were even "reasonable grounds" to believe he was a trafficking victim, because he had not been made to work. It issued a negative decision in November 2022 and refused again in January 2023 after agreeing to reconsider; the High Court quashed that refusal in March 2025. The definition sits in regulation 3 of the 2022 trafficking regulations, covering force or threats used to make a person enable another to acquire a benefit.

What the ruling does not decide

The court did not find AAM is a trafficking victim; that decision returns to the Home Office.

Libya was the most commonly reported overseas country of exploitation in National Referral Mechanism statistics for the year to June 2026, with 7,351 referrals. As of 7 November, the Home Office had made no public statement on the judgment.