PRESS RELEASE – Exploitation on Greek farms: Council of Europe closes 2013 case with no real change

On 3 September, the Council of Europe’s Committee of Ministers has decided to close a 2013 case that saw migrant field workers being shot at in Neo Manolada, Greece, with no further scrutiny. In 2017, Greece was condemned by the European Court of Human Rights for failing to protect the workers, and ordered remedial measures to help prevent further abuse. Advocates denounce no real change has happened to protect migrant workers since.

In April 2013, about 150 undocumented Bangladeshi strawberry pickers were shot, and 30 severely injured, by their employer’s guards as they demanded their unpaid wages. With no papers, the men worked twelve-hour days under the watch of armed guards, often without rest. They were not paid even the promised wages, amounting to about 22€ per working day, which was already well below legal wage limits.

In 2017, the European Court of Human Rights ruled that Greece had failed in its duty to protect migrant workers from labour exploitation, and to properly investigate their abuse and punish those responsible. In its judgement, the court underlined how various changes in policy and practice would be needed to prevent this kind of abuse from happening again and better protect future potential victims.

Three years on, the Committee of Ministers, which oversees the execution of the Court’s judgments under enhanced supervision, has decided to close the case with no further scrutiny.

The Platform for International Cooperation on Undocumented Migrants (PICUM) and the AIRE Centre (Advice on Individual Rights in Europe), and HIAS Greece, have submitted written interventions to the Committee.

While remedial measures have been implemented for the specific workers concerned, and some steps taken to improve anti-trafficking policies, the situation on Greek farms remains essentially the same and is affecting a wider range of migrant workers, including asylum seekers. To meaningfully address ongoing labour exploitation in Greek agriculture, the organisations highlight the need for changes, in particular, in how labour standards are enforced in the fields, in policies around work permits and access to the labour market that currently block migrant workers from working regularly, and in proactive investigations on the part of authorities.

Michele LeVoy, Director of PICUM, said: “In this case our strawberries were being picked literally at gunpoint. In others, the gun might not be there but similar coercion is felt by workers – if standing up for your rights might lead to your arrest… and nothing else – minimal chance of actually getting the wages you are owed or the person being held to account. What we need is for labour rights to mean something in the fields – that they are actually enforced, and enforceable for all workers, without any risk of denunciation or deportation.”

Vassilis Kerasiotis, Director of HIAS Greece, said: In times of COVID crisis it is even more important to address the harsh working conditions of essential agricultural workers across Greece, regardless of their residence status. The new EU Pact on Asylum and Migration should reflect the need for regular migration pathways. Compliance with this landmark judgment should include reforms to Greek immigration laws on residence and work permits for agricultural workers, as a factor to prevent forced labour.”

Morshed (not his real name), a migrant worker, said: When you work, they insult you for no reason. They do not respect working time or break time. I work 3 hours for 5 euros, and have to use chemicals that are dangerous. They give us food that’s already out of date. There is a great deal of discrimination, we are treated differently from other European or Greek workers. They are exploiting us. I’m ready to testify if there would be a way.



  • The final decision of the Committee of Ministers can be found here.
  • Details about the 2013 incident and about the case before the ECtHR can also be found on the website of the Open Society Justice Initiative, which acted as co-counsel to the claimants before the ECtHR. Ongoing monitoring of the situation in Manolada is carried out by Generation 2.0 with the initiative Manolada Watch.
  • PICUM had intervened in the Chowdury case with the AIRE Centre in 2017.
  • Submissions to the Committee of Ministers have been made under Rule 9.2 in the context of the enhanced supervision of the execution of the judgment of the European Court of  Human Rights (ECtHR) in the case of Chowdury and Others v. Greece (App. No. 16643/09, judgment of  30 March 2017).
  • The written submission to the Committee of Ministers from PICUM and AIRE Centre can be found here, and from HIAS Greece here. Submissions have also been made by the Greek National Commission for Human Rights and the Greek Helsinki Monitor.
  • Media requests can be sent to PICUM’s Communications Officer Gianluca Cesaro on
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