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Bombay High Court on Protective Custody of Adult Trafficking Survivors

The Bombay High Court recently delivered an important judgment regarding the protective custody of adult survivors of trafficking, reinforcing constitutional principles of liberty and autonomy.


📜 Background of the Issue

Under the Immoral Traffic (Prevention) Act 1956 (ITPA), courts may place rescued individuals in protective homes for rehabilitation.

However, a recurring legal question has been:

Can an adult trafficking survivor be kept in protective custody against her will?


🏛️ Court’s Key Observations

The Bombay High Court clarified that:

1️⃣ Adult Autonomy Must Be Respected

If a person is a major (above 18 years) and expresses the desire to leave protective custody, continued detention would violate:

  • Article 21 – Right to Life and Personal Liberty

  • Article 19(1)(d) – Freedom of Movement

The Court emphasized that protective custody cannot become illegal confinement.


2️⃣ Distinction Between Protection and Detention

Protective custody is meant for:

  • Rehabilitation

  • Safety from traffickers

  • Temporary shelter

It must not be:

  • Punitive

  • Indefinite

  • Against informed consent


3️⃣ Voluntary Rehabilitation

The Court underlined that rehabilitation must be consent-based for adults. State authorities cannot override an adult’s decision unless there is clear evidence of coercion or incapacity.


⚖️ Legal Principles Involved

The judgment balances:

  • Protection of trafficking victims

  • Individual autonomy

  • State responsibility

  • Constitutional liberties

It reiterates that adult individuals cannot be treated as minors under protective frameworks.


🌍 Broader Context

Human trafficking remains a serious issue in India. Laws such as ITPA and proposed anti-trafficking bills aim to:

  • Prevent exploitation

  • Rescue victims

  • Provide rehabilitation

However, courts ensure these mechanisms comply with constitutional safeguards.


📚 Importance for Competitive Exams

Highly relevant for:

  • Indian Polity (Fundamental Rights)

  • Judiciary & Judicial Review

  • Social Justice

  • Women & Child Protection Laws

  • Current Affairs

Possible questions:

  • Discuss the constitutional safeguards for trafficking survivors.

  • Differentiate between protective custody and illegal detention.

  • Analyze the role of judiciary in protecting personal liberty.


🏁 Conclusion

The Bombay High Court’s ruling reinforces a core democratic principle: protection cannot override personal liberty when the individual is an adult capable of informed decision-making. While the State has a duty to safeguard trafficking survivors, it must do so without infringing fundamental rights.

For Vashishth Academy students, this case is a strong example of how courts balance social welfare legislation with constitutional freedoms.

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