R v. O

O, a Nigerian national and apparently only 17 years old, appealed against a conviction for the offence of possessing a false identity document. One of the submissions on her behalf, supported by a senior outreach worker for The Poppy Project, was that she had been the victim of trafficking for sexual exploitation and used the false identity document in an attempt to escape. The Court of Appeal granted her appeal, stating that it regretted that neither the prosecution nor the defense had considered her age or the possibility that she might have been a victim of sex trafficking at first instance. It was unlawful to impose a prison sentence as such on a person aged 17. Further, the Court of Appeal noted that common law and article 6 of the European Convention on Human Rights alike require far higher standards of procedural protection than were given to O at first instance. The Court of Appeal expressed the hope that the case would drive home the message that proper inquiries need to be made where there is doubt about the age of a Defendant who is a possible victim of trafficking.