Briefing on the Sexual Offences Bill 2003
Women Against Rape
Background

This Bill was presented as an overhaul, intended to address the low conviction rate for rape – currently an appalling 7%. 

Some proposed improvements, such as recognition of oral penetration as rape, rather than a lesser sexual assault, are changes women have long pressed for.  And we are glad to see that there is no attempt to create different grades of rape.

But crucially, the Bill does not adequately tackle the abuse of the notorious defence of “belief in consent”.

The Bill is also problematic in other ways, and its language and structure are convoluted and confusing.  This is no way to get clarity and justice in court, or to send a clear message about what is and is not acceptable behaviour.

This briefing and our proposed amendments only deal with forms of coercion, belief in consent, and disability.  Many of the changes we propose are already in force in other countries, or have been recommended by the Sexual Offences Review or by the Law Commission but are ignored in this Bill.

Belief in consent

Sexual history

The defence of “belief in consent” is qualified by the addition that where there is doubt, the defendant must show that he acted reasonably to establish consent.  This will not stop “belief” being used to attack the woman’s character throughout the trial, thus undermining any gains from this legislation.

The problem in court is that the woman is routinely “put on trial” by the defence and neither the prosecution nor the judge stops it.  Most rapists are men the woman knows, and the most common defence is that she consented, and/or the accused believed that she did.  To justify the defendant’s alleged belief, the woman’s sexual history, lifestyle and mental health records become material to the trial, obscuring the real facts of the case.

When the government Women’s Unit justified this aspect of the law, it caused a furore. 

The Times reported (1 March 1999) that “The Minister for Women, Baroness Jay of Paddington, was at the centre of a row last night over plans to reform the admissibility of the sexual history of a woman victim as evidence in rape trials . . . The Women’s Unit said in a letter to Women Against Rape (WAR): ‘A defendant might claim that he believed the complainant was consenting because he had been told that she always kicked and screamed during sex.  This would be relevant to his honest belief.’” 

The Unit was publicly embarrassed; its director apologised. 

Recent legislative changes have not restricted sexual history evidence enough.  The Youth Justice and Criminal Evidence Act 1999 was supposed to protect women from being cross-examined about their sexual history.  But under that Act such evidence is still allowed whenever the man’s defence is that he believed the woman was consenting.  We were told by Labour women MPs (as this legislation was being finalised) that this problem would be remedied in the overhaul of sexual offences.  But that overhaul – represented by this Bill – does nothing of the sort.

Instead of banning, as we had suggested, the most obviously biased and irrelevant sexual history evidence, that is, evidence that relates to a woman’s sexual history with men other than the defendant, the Youth Justice and Criminal Evidence Act 1999 makes no distinction between sex with the defendant and sex with others.  Again, under this Bill, subsections 1(3)(a) and 78(1)(a) invite the accused to raise any sexual history evidence, including whatever he can find about the woman’s past sex life with anyone at all, to justify his sexist “belief”, i.e. his right to rape.  The mental element of the crime (subsection 2 of the opening clause) begins with belief – not “knows” or is “reckless”, as under the current law.  And since sexual history evidence is not excluded, the accused is immediately invited to raise such evidence to justify his belief.

A reasonable person

Nor can we count on the “reasonableness” of those who conduct the trials, judges or lawyers, defence or prosecution.  Given the history of rape trials, how can we trust them to judge a rapist unreasonable?  These are the same judges who until 1991 considered rape in marriage legal!  In clause 1(3), for example, what is to stop courts deciding that “in all the circumstances” a reasonable person would not doubt B’s consent, because B had happily consented to sex with other men in similar situations, or because of how she was dressed, or because she had been dancing with the defendant earlier in the evening?

Mistaken belief in consent occupies an unjustified central position in the Bill, focusing attention not on what happened – whether the woman actually consented – but on what was in the man’s mind and assumptions he made about her.  Yet in almost every imaginable situation, it is not hard for a man to find out if the woman is consenting.  If she is not clearly enthusiastic, he can ask her. If there is any real evidence that would lead him to a reasonable belief in consent, it will also be evidence that she did consent, and the jury must acquit him.  Mistaken belief is a diversion from the real issue of consent, an excuse to muddy the waters, put the woman in a bad light, or appeal to the prejudices of the court.

The legal establishment has used the principle of criminal intent – that in order to be guilty of the crime the defendant had to know that what he did was wrong – as an excuse for the disgraceful ways in which rape and sexual assault evidence is handled and presented.  The principle of intent has been so distorted in rape cases that courts impose on juries, the perspective, assumptions and calculations of a rapist, thus upholding his crimes and denying justice to his victim.  This would be further maintained by proposed amendments to the Bill stipulating that the “reasonable person” imagined to be making a judgement on consent and on belief, must “share the characteristics of the accused”. 

The debate about “mens rea” has been based on false assumptions.  Men who believe that women “always want it”, or mean yes when they say no, or that wearing a certain kind of underwear means that they consent to sex with anyone under any circumstances, are not making a genuine mistake about the facts.  In Canada it is now being established that they are making a mistake about the law which represents what is acceptable to society.  That kind of mistake is not protected by “men’s rea”.  In accepting the rapist’s perspective, the courts are promoting rape.  Instead, they should be giving men a clear message that sexual contact must be mutually acceptable, and that it is their responsibility to find that out. 

No to segregating victims with “a learning disability or mental disorder”

Although the offences in the Bill (clauses 33-47) were presented in government publicity as completely new, sexual intercourse with a so-called “mental defective” has been a crime at least since 1956. 

We conveyed to the Sexual Offences Review that treating some people with disabilities as a lower form of life in the rape law has been an invitation to discrimination and the non-prosecution of sexual violence against some of the most vulnerable people, especially women and children.  The Sexual Offences Bill has been put forward as answering the Broadmoor scandal which came to light recently (reported in all the main broadsheets in March 2003), where women patients were repeatedly sexually abused by men patients.  Among others, Lord Astor has called for more severe penalties for carers who engage in abusive sexual relationships with patients.  Focussing on care workers does not deal with rape by other patients, as in Broadmoor.

Although “mental defective” is replaced with less abrasive terms in this Bill, nevertheless it maintains the separate category whereby different considerations are brought to the rape and sexual assault of children, women and men with disabilities.  The segregation which the Bill continues, is at the root of how women patients in Broadmoor were treated, and the non-prosecution of the attacks they reported.  Many of the women, most of whom were survivors of earlier violence, were raped and sexually assaulted by men patients detained for committing horrific crimes.  Staff who allowed this violence to go on drove a woman manager out of her job for blowing the whistle, though she later won compensation.

Assaults are rife on those of us who are this vulnerable, but hardly any cases get to court.  Police called in to investigate sexual assault by men bathing women in care homes are no longer interested once they find out the complainant has Alzheimer’s Disease.  Psychiatric hospitals refuse to take responsibility for the rape of women patients, or to confine rapist patients, and refuse to bring in truly women-only wards.

We propose an amendment which starts to protect victims with disabilities under the mainstream definition of sexual offences, and we have put the principle of lack of consent into the care worker offences -- there are always problems when outsiders are able to invoke the criminal law where the victim is apparently consenting, has not made a complaint herself and cannot prevent a prosecution even if that prosecution is against her will.  What we really need is the abolition of separate offences based on disability status so that all women with disabilities have the full protection of the law.

Amendments to the Sexual Offences Bill 2003

Clauses 43-47 - Care workers’ sexual activity with a person with a mental disorder or learning disability, and similar offences

Amendment to all clauses:
Replace (c) “B has a mental disorder or learning disability” with “B is unable to refuse because of a mental      disorder or learning disability, as defined in 33(2)”.

Rationale:
The offences dealing with care workers leave out the requirement in the other disability-related offences that the person is “unable to refuse”.  Without our amendment (copied from the disability-related offences), the crime arises from the care relationship, not from lack of consent.  Consenting relationships should not be prosecuted. 

Clause 77 – Consent

Amendment:
“A person consents if s/he is willing, without coercion, and informed, without deception.”

Rationale:
Having the capacity to understand is not the same as being informed, that is, having the relevant information.  And a person can be free (able) to decide to do something, without being willing. The Bill’s definition is that he “agrees by choice, and has the freedom and capacity to make that choice.”  These terms are much more subjective than in our amendment.

New clause – insert:

“If at a trial a person charged with a sexual offence is seeking to establish that s/he believed the complainant consented, then
(a)  no evidence may be adduced, and
(b)  no evidence may be asked in cross-examination
by or on behalf of any accused at the trial, about any sexual behaviour or sexual experience of the complainant with any person other than the accused.”

Rationale:
Legislation should ensure that men’s unreasonable belief in women’s consent does not give them licence to rape.  A man cannot reasonably conclude that, because of something a woman consented to with another person, she consents to an activity with him.  Any such conclusion is unreasonable.  It is not admissible and is therefore no excuse for allowing a women’s sexual history to be brought into court to degrade, intimidate, and discredit her.  We know of no other jurisdiction which allows sexual history evidence on this basis.

Clause 78 – Presumptions about the absence of consent

Amendment:
Leave out clause 78 (1)(a) and insert instead:
“78(1)(a) the complainant is taken not to have consented to the relevant act unless the defendant adduces evidence that s/he consented on that occasion.”

Rationale:
In cases where the defendant has used or threatened violence or where the complainant was asleep or unconscious, we do not see why her consent should be presumed any more than his belief, which the Bill already says is up to the defendant to “prove”. Many other jurisdictions, and Protecting the Public, have accepted that in such circumstances the burden of proof should fall on the defence. In this Bill, by contrast, all he has to do is “raise an issue” – as under current law.[1] This is another invitation to attack the woman in court.

[1] Criminal Injuries Compensation Authority backed man who raped family friend who was asleep

Mrs Y was raped whilst sleeping, having drunk substantial amounts of alcohol. The accused – a friend of a friend – was acquitted in court.  WAR was asked to help her appeal the refusal of compensation.  Compensation had initially been refused on the grounds that “no crime of violence” had taken place.  The compensation Board wrote that “the reactions of Mrs Y were not, as she acknowledges, demonstrably unwelcoming for some time, albeit measured in minutes.”  She had given him “no signal of absence of consent” (until she woke up fully and threw him off the bed).  WAR represented her at appeal, arguing that it goes against the principle of rape law that the absence of a “signal” meant he could take advantage of her while she was asleep.  We also objected to their saying “there is an indication of a relationship having developed in which it was not unreasonable for the defendant to at least consider that the exchanges might progress to sexual intimacy”.  This is a typical case of where the man’s belief in consent was used by a legal authority to override the woman’s actual refusal of consent.  With our help, she won compensation of £7,500. 

Amendment:
Subsections (3)(a) and (3)(b): Delete the word “immediate”.

Rationale:
Many threats are not immediate but are as potent to the victim.  Assumptions that if a threat is not immediate, the woman can access protection from the police and other authorities, have repeatedly been proved wrong, and women have died as a result.

Amendment:
Add these other important circumstances to Subsection (3):
“The person submits through fear of harm of any kind, to themselves or to another person, including because of
 
-Threats relating to the complainant ’s children;
   -Financial deprivation, or threat of this.
Abuse of authority;
Abduction, including threat by a father to abduct a child away from its mother.”

Rationale:
These are common abuses of power used by rapists. If you are raped by a person in authority (e.g. a police officer), you are less likely to report it, and less likely to be believed.  Rather than simply “against another person”, the Bill should specify threats to children to force women into unwanted sex, especially since this is commonly used by violent ex-partners.  Men also threaten women with financial deprivation which affects our children.  The first concern of a mother is her dependants’ welfare. The coercion specified in 3(a) and (b) is limited compared to other jurisdictions.  Submission is not the same as consent.

Amendment:
After (e), which deals with complainants who, because of physical disability, are unable to communicate whether they consent, add:
“(f) people with learning disabilities or mental disorder.”

Rationale:
Treating victims unable to consent as outside the mainstream rape law, has not protected victims with disabilities.  Prejudiced considerations are brought to bear, leading to dropped investigations.  Our amendment helps to bring vulnerable victims into the mainstream and allows for individual circumstances to be aired in court.

Amendment:
Leave out Clause 78, subsection (5) and substitute:
"78(5) In deciding whether or not the defendant acted in a way that a reasonable person would consider sufficient in all the circumstances to ascertain whether the complainant was consenting, the jury should be directed not to consider the following evidence:
(i)    evidence of anything said or done by a third party, or
(ii)   evidence of the complainant's past sexual behaviour or experience with any person other than the defendant"

Rationale:
As it stands, subsection (5)(b)(i) bans third party evidence where it is the only evidence put forward, but allows it to be raised if it is together with something the accused saw for himself, for example, the way the woman was dressed.  This is unacceptable and will continue to provide a vehicle for outrageous justifications of rape in court.

Evidence of the woman’s sexual history with other men should be largely excluded by the new clause proposed above, which removes a defence of “belief in consent” as an excuse for bringing in this evidence.  Under criminal evidence law, sexual history may still be raised for other reasons.  This is not to be taken as evidence of consent.

Amendment:
Leave out clause 78(8)(a)
Leave out clause 78(8)(b) and substitute:
“The defendant intentionally induced the complainant to consent to the relevant act by deception, or by impersonating a person known personally to the complainant.”

Rationale:
It is not only deception as to the nature of the act, or the person involved, that can lead to rape.  Please see the moving personal testimony attached. 

Mandatory Judges’ Directions

New clause:
“In every case where evidence or questioning about a woman’s sexual history is permitted by the judge, a mandatory warning must be issued by the judge to the jury making clear that
(a)  consent to activity with one person does not prove consent to activity with any other person, and
(b)  consent to activity with the accused on one occasion does not prove consent on any other occasion.”

As recommended in Setting the Boundaries (para 2.1.3), there should also be a mandatory direction along the lines of that used in Victoria and in the Australian Model Criminal Code to establish that:

New clause:
“A person is not to be regarded as consenting to a sexual act just because
- the person did not say or do anything to indicate they did not consent, or
- the person did not protest or physically resist;
- the person did not sustain physical injury;
on that or an earlier occasion, the person had consented to engage in a sexual act (whether or not of the same type) with that person or a sexual act with another person.”

Rationale:
Many judges have proved themselves biased in rape cases, and promote, rather than challenge, sexist assumptions.  Mandatory warnings are some protection for the rape survivor that prejudices will be challenged in court and that juries must put their prejudices aside when considering the evidence.

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