LR v The Secretary of State for the Home Department
| Court | Upper Tribunal (Immigration and Asylum Chamber) |
| Judgment Date | 13 August 2026 |
| Neutral Citation | [2026] UKUT 315 (IAC) |
| Date | 13 August 2026 |
| Year | 2026 |
© CROWN COPYRIGHT 20262026
NCN: [2026] UKUT 00315 (IAC)
LR (Male VOTs) Albania CG
IN THE UPPER TRIBUNAL
IMMIGRATION AND ASYLUM CHAMBER
Heard at Field House
THE IMMIGRATION ACTS
Heard on 9-13 March,18-20 March and 27 July 2026
Issued on 13 August 2026
Before
DEPUTY CHAMBER PRESIDENT PLIMMER
UPPER TRIBUNAL JUDGE BLUNDELL
UPPER TRIBUNAL JUDGE LANDES
Between
LR
(ANONYMITY ORDER MADE)
Appellant
and
THE SECRETARY OF STATE FOR THE HOME DEPARTMENT
Respondent
Representation:
For the Appellant: Zane Malik KC, Tom Tabori and Paul Erdunast of counsel, ins tructed by
Thompson & Co Solicitors (Tooting)
For the Respondent: William Hansen (up to 20 March 2026), Karen Reid (for the hearing on 27
July 2026) and Gemma Ralph of counsel, instructed by the Government
Legal Department
Order Regarding Anonymity
granted anonymity. No-one shall publish or reveal any information, including the name or
address of the appellant, likely to lead members of the public to identify the appellant. Failure to
comply with this order could amount to a contempt of court.
(1) Profile. There is no typical profile for Albanian male victims of trafficking (‘VOTs’). Certain
common themes are encountered amongst those who have been trafficked. Often they tend to: be
2
teenagers or young adults; come from less affluent or marginalised backgrounds; have received
a limited education; have experienced domestic violence or neglect. However, male VOTs might
become vulnerable to trafficking for a variety of reasons, and come from all parts of Albania and
from varied social backgrounds.
(2) Risk factors. The following non-exhaustive list of risk factors may lead an Albanian male to
become a VOT:
(i) Lower socio-economic status including homelessness
(ii) Lower levels of education and difficulty in securing legitimate employment
(iii) Ill health, whether physical or mental, including addiction
(iv) Originating from Northern Albania or a rural area
(v) Age, with younger men and teenagers being more vulnerable
(vi) A lack of a family or other support network, whether by reference to blood feud, criminality
or adverse childhood experiences
(vii) Belonging to a minority ethnic group or having an LGBT identity
(3) It is important to bear in mind that the presence of multiple factors may compound or increase
risk but one risk factor may be sufficient to make a person a VOT.
(4) Modus operandi. Male VOTs are lured or forced into trafficking in a variety of ways including
(but not limited to) the following: a young male finds himself in financially straitened
circumstances, accepts an offer of claimed lucrative employment in the UK, only to discover en
route or on arrival that he is to be exploited and forced to work in difficult and unlawful
conditions, whether as a result of debt bondage, family pressures or because of threats to his
safety or that of his family.
(5) Social media plays an increasing role in the initial recruitment process. Organised Criminal
Networks (‘OCNs’) are likely to play a role in such trafficking, although it will be for an
individual decision maker to consider the nature and extent of that role in a case in which it is
disputed. Trafficking by means of abduction is not commonplace.
(6) Risk on return. An individual who escapes from a situation of trafficking or otherwise manifests
an unwillingness to be involved in drug-related or other criminality may be at risk on return to
Albania. He might be at risk of re-trafficking and/or reprisal at the hands of his original
traffickers or at risk of re-trafficking at the hands of another.
(7) It is not possible to quantify the risk of re-trafficking in any given case, whether at the hands of
the original traffickers or at the hands of another. In considering the extent of any such risk, a
decision maker who is satisfied that an individual has been the subject of past persecution or the
threat thereof will consider that fact to be a serious indication of the risk of future harm unless
there are good reasons to consider that it will not be repeated (paragraph 339K of the
Immigration Rules refers).
(8) In considering the risk of re-trafficking or reprisal from the original traffickers, it will be
necessary for decision-makers to consider:
(i) The circumstances of the individual and in particular his vulnerabilities, together with the
reintegration assistance which is likely to be provided to the individual on return to
Albania. In considering vulnerability to re-trafficking by deception, it will be relevant to
consider that an individual who was previously duped by a trafficker will be aware of the
risks associated with offers of the kind.
(ii) What is known about the original traffickers, in particular:
(a) the size of the operation and its level of organisation;
(b) any threats which have been made or acted upon in the past, including in relation
to debt bondage;
(c) any connection to family members and acquaint ances;
3
(d) any links to the community / area the individual and his family members originate
from;
(e) the extent to which the indiv idual has tangible evidence against an Organised Crime
Group (‘OCG’) which might jeopardise its future operations
(f) the passage of time (because a significant period without interest or threat may
indicate a lack of ongoing interest).
(9) In assessing the risk of re-trafficking at the hands of a different actor, decision makers should
take account of the individual’s original risk profile and vulnerabilities and the extent to which
this has changed or is likely to do so. In considering vulnerability to re-trafficking by deception,
it will also be relevant to consider that an individual who was previously duped by a trafficker
will be aware of the risks associated with offers of the kind.
(10) Aids and obstacles to reintegration. There is no shelter provision for individual adult male VOTs.
A returning adult male VOT who is not able or willing to return to their family must rely upon
accommodation in the rented sector with the assistance of NGOs. Such support is provided after
initial identification as a VOT by an NGO and without the need for a formal declaration of that
status.
(11) The normal offer of rented accommodation from an NGO is limited to six months, but the
occasional need for longer term help is likely to be able to met. Whilst the NGOs current capacity
for male VOTs is relatively limited, there are clear indications that should there be a need to
increase capacity, support is scalable with the necessary funding and lead-in time to recruit
and train additional staff. The NGOs are widely acknowledged to be supportive and to assist
VOTs proactively and positively and without discrimination.
(12) Once a VOT leaves the rented accommodation provided by NGOs, they are required to obtain a
formal declaration of their status in order to access the support provided by the Albanian state.
Such declarations must be obtained by attending an interview with a specialised police officer
and a social worker. There is a comprehensive and detailed framework of provision to support
recognised VOTs with reintegration including the National Referral Mechanism (‘NRM’) and
Standard Operating Procedure (‘SOP’) as well as some support in employment, limited financial
assistance, livelihood skills, housing and access to healthcare.
(13) The institutional framework is bolstered by initiatives undertaken by NGOs who will assist
male VOTs to access state or municipal reintegration support, but also run their own support
programmes including fulfilment of basic needs, housing support, financial aid to start a small
business and psychological counselling.
(14) For each reintegration measure available, there are practical challenges associated with access
to the measure. Whilst VOTs are a priority group for social housing and rent subsidies, and
NGOs will assist the VOTs to access what is available, there are many other priority need
categories and state and municipal funding may simply not be available for such programmes.
(15) In addition, VOTs may encounter a range of obstacles to access these aids to integration.
Prevailing social mores discourage an adult male VOT from seeking reintegration support. As a
result of the support offered by the NGOs, however, it will generally be reasonable to expect an
adult male VOT to identify himself as such on return, so as to access the support available from
NGOs and, subsequently, the Albanian state. An adult male VOT may however be able to
establish that it would be unreasonable to expect him to access that support on account of
particular vulnerability, including genuinely-held subjective fear, mental health problems,
disability or membership of an ethnic minority group.
(16) Sufficiency of protection. The Albanian government has made significant further efforts to
improve its response to trafficking and VOTs and there is a general sufficiency of protection for
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