ABSTRACT
In Iversen v Norway 1963,841 a dentist in Norway was ordered by the government to work in an isolated village in the north of the country for a year. A majority of the Commission decided that the case was manifestly illfounded. Some of the members felt that this was not forced or compulsory labour at all, but some felt that the case fell within para 3(c). In W, X, Y, and Z v UK 1968,842 the Commission held that young men who joined the Navy at 15 for fixed periods of over 10 years could not claim a breach of the article. Their case was not automatically covered by the exemption at (b), but the arrangement could not be classified as ‘servitude’ when parental consent had been given. Van der Mussele v Belgium 1983843 concerned a Belgian practice of requiring trainee barristers to represent poor people without a fee. The court considered that this was not compulsory labour. The applicant’s voluntary entry to the profession was insufficient to exempt it; but the services in question were normal professional activities, part of his training and not disproportionate.
