Court ruling10/17/2026

Supreme Court Upholds Conviction for Trafficking in Persons for the Purpose of Prostitution

The Supreme Court of Israel dismissed Michael Freudenthal’s appeal against his conviction for trafficking in persons for the purpose of prostitution. The Court held that transferring women into his control in exchange for a share of the proceeds falls within the definition of trafficking in persons, even if it was not formally conducted as a sale transaction.

Key facts

•Case: CrimA 11196/02
•Court: Supreme Court of Israel
•Decision: August 13, 2003
•Lower-court case: CrimC 1064/02
•Sentence: 24 months’ imprisonment and 18 months’ suspended imprisonment
•Statutory provision: Section 203A(a) of the Penal Law, 5737–1977

What Happened

Freudenthal admitted the facts in the amended indictment but argued that, at most, they proved pimping. According to those facts, in February 2002 another defendant transferred two women to him for the purpose of prostitution, with their knowledge and consent. Freudenthal housed them at his premises, took bookings, drove them to clients, collected payment, and prohibited them from leaving the apartment without permission and supervision.

How the Money Was Divided

From each client, the woman received 40 shekels, Freudenthal kept 40 shekels, and he transferred 60 shekels to the first defendant during weekly meetings. In addition, each woman paid him 20 shekels per day for accommodation and food. The amended indictment also stated that he threatened to return the women to the first defendant and to harm them and their parents if they contacted the police.

Why This Was Recognized as Trafficking in Persons

The defense argued that Section 203A(a) of the Penal Law, 5737–1977, applies only to sale and purchase in their narrow civil-law sense. The Supreme Court rejected this approach: a person cannot be regarded as property, and therefore the terms sale and purchase in this context encompass any arrangement for consideration that creates a quasi-proprietary right in another person. This includes transfer of possession, rental, lending, partnership, and other forms of control, where the person becomes the object of a transaction for the purpose of prostitution.

The Court’s Decision

The Court held that the transfer of the women into Freudenthal’s control and the agreement to divide the proceeds created a proprietary relationship of this kind. Accordingly, his acts constituted not only pimping, threats, and unlawful deprivation of liberty, but also trafficking in persons. The appeal against the conviction and sentence was dismissed; the sentences imposed—24 months’ actual imprisonment and 18 months’ suspended imprisonment—remained unchanged.

What this means for you

For an act to be classified as trafficking in persons, there is no need for a formal sale of a person or the transfer of full ownership rights. Transferring a person into another’s control in exchange for money, a share of the proceeds, or another benefit may be considered trafficking in persons if the person becomes the object of a transaction for consideration for the purpose of exploitation in prostitution. Pimping differs in that it concerns profiting from sexual services, whereas trafficking in persons involves a transaction concerning the person themself.

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Case analysis based on court rulings