Laura Deuxberry wins Court of Appeal case on sex trafficking

22nd April 2026

Laura Deuxberry, 3PB's criminal, regulatory and public law barrister, was instructed by the CPS Special Crime Division in London, led by Kevin Dent KC, in the recent case of How and Yang [2026] EWCA Crim 476.

Appearing in the Court of Appeal, the appellants argued that the original trial judge, HHJ Ashworth, should have allowed their submission of no case to answer on the trafficking charge.

The Court of Appeal heard the appeal of the two appellants, one of whom had been earlier sentenced to imprisonment in his absence, in a case which revolved on the point of construction and meaning of Section 2 of the Modern Slavery Act (MSA) 2015.

The appellants' counsel argued that in order to prove an offence under section 2 of the MSA 2015, the prosecution had to prove that the accused had trafficked a sex worker in the sense described in Article 4 of ECAT, which included the ‘means’ by which the sex worker was trafficked. The Prosecution accepted at the trial that was no direct evidence of ‘means’ but had argued that Section 2 of the MSA 2015 was clearly worded and that there was enough evidence for a jury to conclude that the sex workers were being trafficked when the appellants arranged for them to travel for sex work in order to control their prostitution.

The Court of Appeal agreed with Laura Deuxberry and Kevin Dent KC’s submission that the "plain words of the MSA 2015 and the absence in them of any limiting reference requiring proof that the travel was arranged or facilitated by the particular means identified in Article 4 of ECAT". The Court of Appeal therefore dismissed the appeals and held in favour of the CPS' Special Crime Division.

To contact or instruct Laura, please email Chambers Director Stuart Pringle on [email protected] or telephone 01962 868884.