Lessons, Chapter 1


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Reducing teenage pregnancy • A great moral evil • 'Christian' version of sex education • Amoral ideology of sex education

Initiatives to reduce teenage pregnancies

Chapter 1 from Lessons in Depravity by ES Williams

  The Social Exclusion Unit's report on teenage pregnancy: the Government's guidance to schools on sex education

The UK has the highest rate of teenage pregnancies in Western Europe. The Prime Minister, in his foreword to Teenage Pregnancy – a report of the Government’s Social Exclusion Unit – writes: ‘It is not a record in which we can take any pride. Every year some 90 thousand teenagers in England become pregnant. They include nearly 8 thousand who are under 16… As a country we can’t afford to continue to ignore this shameful record. Few societies find it easy to talk honestly about teenagers, sex and parenthood. It can seem easier to sweep such uncomfortable issues under the carpet. But the consequences of doing this can be seen all round us in shattered lives and blighted futures.’1  The Prime Minister does not believe that young people should have sex before they are 16. ‘I have strong views on this. But I also know that no matter how much we might disapprove, some do.’2 He continues: ‘It shows how we can and must improve education on relationships and sex for teenagers. We must give teenagers the confidence and the information so they don’t feel compelled to have sex. No one should become pregnant or contract a sexually transmitted infection because of ignorance.’3

Because the Government believes that the answer to unintended teenage pregnancies lies in more easy access to condoms and emergency contraception, the Department of Health has just announced a plan which encourages secondary schools to give pupils free condoms and contraceptive pills. The chief executive of the Family Planning Association, Anne Weyman, welcomed the Government’s acceptance of the recommendation that ‘health services’ should be provided on site in schools. She said, ‘The rate of teenage pregnancy in this country is too high and action to bring it down is essential. Measures such as this are eminently sensible.’4

Another initiative to reduce teenage pregnancies is a condom card scheme which allows children as young as 13 to collect condoms free of charge and without their parents’ knowledge from drop-in community centres. To receive their condom card a boy or girl fills in a registration form and then presents the card to collect a pack of 15 condoms. Each child is entitled to an unlimited supply, although clinic staff try to monitor the number of condoms being handed out. A 16-year-old boy expressed his delight with the scheme in a national newspaper: ‘No one can stop young people having sex whether they are teachers, the police or parents. It’s a fact of life.’ Equally enthusiastic about the scheme, known as Sexual Health Outreach with Teenagers, was the teenage pregnancy co-ordinator for Sunderland Health Authority. ‘We have seen girls as young as 12 getting pregnant and if you are trying to tackle that then you need to start in schools at an early stage. What we are trying to do is to send health professionals into schools to train teachers so each school will have a teacher trained in family planning or a family planning nurse. There is no need legally to inform parents if a young person asks for contraception. It can be given without parental consent. However, we encourage young people in such situations to talk to their parents.’5

The board game, Contraception, which has been developed in line with the Government’s sex education guidelines, is another enterprise for teaching children about contraceptives. The aim of the game, which retails at £50, is to encourage children to talk to each other about ‘safer sex’ in a relaxed, enjoyable group setting.6 Children throw dice to move their counters, shaped like condoms or packets of pills, around the board. Players come into contact with various contraceptive and sexual health services, condom machines and family planning clinics. They are directed to make assertive statements to strengthen their ability to express their own needs and decline unwanted pressure. Peer education is a feature of the game. During their progress around the board they are presented with a ‘question’ card which offers two options—the choice might be between using a condom demon-strator to teach the group how to unroll a condom, or answering a question about sex. Two examples of the type of statements presented for discussion by the ‘safe’ cards are: ‘You do not have a partner tonight but are going to a party and you feel safer carrying a condom’7 and, ‘Your partner does not seem to enjoy sex. You show him/her lots of affection and start to talk about sex in your relationship.’8

The pupils of Crompton House Church of England school in Oldham are apparently enthusiastic about the game. According to a 13-year-old boy, sex is on a lot of teenagers’ minds and the game was a good way of finding out about contraception and ‘safe sex’. ‘If you’re a quiet person, it may be hard to talk about sex. This game provides a way of talking about it without embarrassment.’ The head teacher, David Bowes, said the game had proved highly accessible for teenagers, many of whom would make a decision about sex sooner than teachers would wish. What he liked was that the children were in control. They were the decision-makers.9 He went on, ‘There is nothing salacious or unpleasant about this game – I can see it forming a part of our sex education classes in future.’10

The programme, Adding Power and Understanding to Sex Education, commonly known as A Pause, has been developed by Exeter University and is backed by the Departments of Health and Education. The aim of A Pause, which is now running in about 150 secondary schools around England, is to help ‘young people in their decision to delay intercourse until a time when they are less likely to regret it, assisting them to negotiate stages of intimacy, appropriate contraception and access to services’.11 According to the programme director, John Rees, it was about getting 14 and 15-year-olds to think about stages of intimacy that did not involve penetrative sex, with its risks of pregnancy and infection.12 He added: ‘It’s about saying to them. “You can hold hands, you can kiss and cuddle”, it may even get as far as something like oral sex or even mutual masturbation.’13 Teachers involved with A Pause are trained to handle frequently asked questions, such as a 14-year-old girl asking: ‘What does semen taste like?’ Or a 15-year-old boy: ‘How do gay men have sex, and is it possible for a man and woman to do it the same way?’14 The underlying aim is to encourage school pupils to think about oral and anal sex and mutual masturbation as alternatives to sexual intercourse. The theory is that if children can be taught the pleasures of non-penetrative sex they will be less likely to indulge in vaginal sex, thereby reducing the rates of teenage pregnancy.

Another Government scheme piloted the provision of emergency contraception in supermarkets. In March 2002, two Tesco stores in north Somerset announced that any girl under the age of 20 would be able to pick up the ‘morning-after’ pill at the pharmacy counter, although she would be subjected to a detailed interview. Vicky O’Loughlin commented on behalf of North Somerset Primary Care Group, ‘Some people, even in Weston, do have sex. What this is about is offering services that they can access, as sometimes it is difficult to go to their GP.’15 After objections from customers and a number of pro-life organisations, Tesco announced that it had decided not to dispense emergency contraception to under-age girls from in-store pharmacies. A month later Sainsbury’s announced that five stores in areas with high teenage pregnancy rates had entered into partnership with local health authorities to make emergency contraception available free of charge to teenagers, including girls under 16. A Department of Health spokeswoman said, ‘We strongly support the involvement of Sainsbury’s, working in partnership with the local NHS, to improve young women’s access to free emergency contraception.’16

Yet another initiative allows school nurses to give under-16s emergency contraception without the knowledge of their parents. The manager of East Kent Community NHS Trust, an area with a high rate of teenage pregnancies, explained, ‘It covers any age group, but nurses have to run through several issues with the girls and check that they know what they are doing.’ Acknowledging that nurses faced difficult situations when very young girls asked for emergency contraception, she said, ‘We would obviously have to look at child protection issues. The parents will not be told unless we believe the child is at risk in some way and the parents need to be informed.’17

Clearly, a key aim of the Government’s teenage sexual health strategy is to ensure that children have easy access to contraceptives and, in case of a slip-up, access to emergency contraception. So sexually active children are reassured that the Government is doing all it can to help them avoid unintended pregnancies—they know that if they forget to take their contraceptive pills regularly or have a condom ‘accident’, the ‘morning-after’ pill is available from supermarkets and school nurses. And because contraceptive services for children are confidential, they don’t have the worry that their parents might find out.

Teenage Pregnancy Report (1999)
The report of the Government’s Social Exclusion Unit, Teenage Pregnancy, provides a national plan to halve the number of teenage pregnancies within the decade. It offers three reasons for the high rate of unintended pregnancies. The first is low expectations among teenagers. ‘One reason why the UK has such high teenage pregnancy rates is that there are more young people who see no prospect of a job and fear they will end up on benefit one way or the other.’18 The report shows that poverty is a key risk factor for teenage pregnancy. The risk of becoming a teenage mother is almost ten times higher for girls whose families are in social class V (unskilled manual), than those in social class I (professional). Other risk factors are: children of a teenage mother, children in care or leaving care, children with educational problems, and teenagers of 16 and 17 who are not in education, training or work.19

A second reason advanced for the high teenage pregnancy rate is ignorance. We are told that ‘young people lack accurate knowledge about contraception, sexually transmitted diseases, what to expect in relationships and what it means to be a parent’.20 The premise that underlies this assertion is that sexual activity is the norm for teenagers. It follows that those who lack ‘accurate knowledge about contraception’ are at high risk of a teenage pregnancy, while those who have ‘accurate knowledge’ are able to protect themselves. And so sex education, which provides children with ‘accurate knowledge’, helps to prevent teenage pregnancies.

A third reason given for teenage pregnancies is mixed messages. ‘As one teen-ager put it to the Unit, it sometimes seems as if sex is compulsory but contraception is illegal. One part of the adult world bombards teenagers with sexually explicit messages and an implicit message that sexual activity is the norm. Another part, including many parents and most public institutions, is at best embarrassed and at worst silent, hoping that if sex isn’t talked about, it won’t happen. The net result is not less sex, but less protected sex.’21 The Social Exclusion Unit is creating an impression of ignorant, confused children who are having lots of unprotected sex. The inference is that it would be a good thing if more of these children could be persuaded to use contraception. What is disingenuous about this analysis is that it takes no account of the dramatic increase in contraceptive usage among teenagers that has occurred during the last decade (see figure 1, page 8).

The conclusion of the Teenage Pregnancy report is that the factors mentioned above ‘point to a single fault line in past attempts to tackle this problem: neglect. Governments and society have neglected the issue because it can easily drift into moralising and is difficult for anyone to solve on their own.’22 According to the assessment of the Social Exclusion Unit the past three decades of sex educa-tion have amounted to neglect. And worse, there has been a drift into the most serious error of all—moralising. So young people have not only been neglected, but have also been threatened by the moralisers. The Government’s action plan makes it plain: ‘Preaching is rarely effective. Whether the Government likes it or not, young people decide what they’re going to do about sex and contraception. Keeping them in the dark or preaching at them makes it less likely they’ll make the right decision.’23 Here the Government is asserting that there is no point in teaching moral standards, for young people are apparently impervious to the restraints imposed by biblical morality and simply make up their own minds how they should conduct their sexual lives. Moreover, not only is moral teaching of no value, it may even be counterproductive in that it antagonises young people, making it less likely that they will make the right decision.

Another problem identified by the Teenage Pregnancy report is that the parents are not talking to their children about sex. ‘During the Unit’s consultation, parents repeatedly said that they felt embarrassed and ill-equipped to broach this subject with their children, and this was made worse for many by knowing little about what was taught at school.’24 The claim is that most parents are not receiving advice on how to address issues of sex and sexual health with their children. The picture that emerges is of growing numbers of young teenagers drifting into sexual relationships because of weaknesses in the sex education they receive from school and their parents. In order to overcome this problem the Department of Health plans to commission a national campaign to help parents talk to their children about sex.25

Having dismissed the moral dimension, the Social Exclusion Unit goes on to inform us how the Government plans to achieve its goal of reducing teenage pregnancies. The action plan includes a national campaign involving Government, media and others ‘to improve understanding and change behaviour’. The campaign ‘will target young people and parents with the facts about teenage pregnancy and parenthood, with advice on how to deal with the pressure to have sex, and with messages that underline the importance of using contraception if they do have sex’.26

Local areas have already appointed ‘teenage pregnancy co-ordinators’ whose task is to pull together all the services that have a role in preventing teenage pregnancy. All local authorities and health authorities in England are jointly required to produce a teenage pregnancy strategy, stating the actions they intend to take to meet the national target for reducing teenage conceptions. The Family Education Trust analysed 23 such locally produced strategies and found a disappointing lack of originality. ‘They all start from the basic premise that young women become pregnant because they are ignorant about the facts of life, and are either unable to obtain contraception or unaware of why it should be used. The answer, therefore, is seen to be more sex education and easier access to contraception.’27 All the strategies point out that sex education is already being delivered in schools in their area. ‘The plan, therefore, is to take it lower down the age range, to primary schools, to make it more comprehensive within the school curriculum… This type of sex education is linked to the provision of contraception, and there is a stated intention in a number of these strategies to use school nurses and clinics for this purpose.’28

A national telephone helpline has been set up ‘to give teenagers advice on sex and relationships and to direct them to local services’. A publicity campaign will tell young people ‘they can talk to health professionals about sex and contraception in confidence’.29 And teenagers who become parents ‘should not lose out on opportunities for the future’ and will be helped to finish their full-time education.30 Funding of £60 million over the next three years has already been earmarked.31

Sex and Relationship Education Guidance (2000)
The Government’s Sex and Relationship Education Guidance was issued to all schools and health authorities in England in July 2000. The guidance makes it clear that the objective is ‘to help and support young people through their physical, emotional and moral development’ and to help ‘pupils deal with difficult moral and social questions’.32 Young people should ‘develop positive values and a moral framework that will guide their decisions, judgements and behaviour [my italics]’.33 Sex education should focus on ‘the building of self-esteem’.34 Young people should learn ‘the reasons for delaying sexual activity, and the benefits to be gained from such delay; and the avoidance of unplanned pregnancy’.35 They should also ‘understand the reasons for having protected sex’.36 They should be provided ‘with information about different types of contraception, safe sex and how they can access local sources of further advice and treatment’.37 (In this context, ‘treatment’ means a prescription for contraceptives.)

The essence of the Government’s approach is to give children a large amount of information about sex and invite them to make an informed choice between delaying sexual activity and having ‘protected’ sex. This approach is sometimes referred to as ‘comprehensive sex education’ in that it gives children all the information they need to make ‘informed’ sexual choices. So we see that an important dimension of sex education, despite its concern about the ‘moralisers’, is to deliver a moral message that influences the informed choice that children make with regard to their sexual conduct. In the next chapter we examine the moral philosophy that underpins sex education.

Another objective of school sex education is to teach that marriage and ‘other stable relationships’ are moral equivalents. The Government makes it absolutely clear that children are to be taught ‘that there are strong and mutually supportive relationships outside marriage. Therefore pupils should learn the significance of marriage and stable relationships as key building blocks of community and society.’38 The implication of this message is that marriage is but one type of stable relationship—other ‘stable relationships’ include cohabitation and same-sex relationships.

Sex education aims to help children to overcome their natural embarrassment and talk about sex. ‘It is essential that schools can help children and young people develop confidence in talking, listening and thinking about sex and relationships. Teachers and other staff may need to overcome their own anxieties and embarrassment to do this effectively.’39 The message is that it is important for teachers and children to overcome embarrassment so that they feel comfortable talking openly about sex.

Teaching children about contraception is at the heart of sex education. ‘Knowledge of the different types of contraception, and of access to, and availability of contraception is a major part of the Government’s strategy to reduce teenage pregnancy.’ It follows that ‘trained staff in secondary schools should be able to give young people full information about different types of contraception, including emergency contraception and their effectiveness… Trained teachers can also give pupils – individually and as a class – additional information and guidance on where they can obtain confidential advice, counselling and, where necessary, treatment.’40 This means that children are to be given instruction in using contraception and emergency contraception, and teachers can give children confidential advice about where to obtain contraception. According to the guidance, ‘young people need to know not just what safer sex is and why it is important but also how to negotiate it with a partner’.41 The ability to negotiate ‘safer sex’ is an important skill that sex education hopes to impart to teenagers.

Contraceptives and the ‘morning-after’ pill for children
The Government’s campaign to increase the use of both contraception and the ‘morning-after’ pill among children must be seen in the light of current patterns of usage. While sex education guidance creates the impression that children are having difficulty accessing contraception, and the Social Exclusion Unit claims that some young people actually think that it is illegal for them to use contraceptives, an examination of the statistics shows a different picture. During the last 25 years there has been a tenfold increase in the number of English girls under 16 using contraception (figure 1). In the year 1975, around 8 thousand girls were recruited into contraception; by the year 2001 the figure had risen to 80 thousand. In the same year, about 48 thousand 15-year-olds (that is, 16 per cent) attended family planning clinics.42 Despite these alarming statistics the Government is doing all in its power to increase still further the use of contraceptives among children.

The use of the ‘morning-after’ pill (emergency contraception), which the Government is pushing so hard among under-age children, has shown an equally dramatic rise since it became available in the early 1980s. About two-thirds of prescriptions are issued by GPs and one third by family planning clinics, and by the mid-1990s the annual number of prescriptions for the ‘morning-after’ pill in England was just under 800 thousand. In the year 2001, family planning clinics issued nearly 26 thousand prescriptions for the ‘morning-after’ pill to girls under 16,43 while the number obtaining GP prescriptions is not recorded.

So how successful has contraception been in preventing teenage conceptions? How many of the 8 thousand under-16s who became pregnant in 2001, and how many of the 26 thousand under-16s who used emergency contraception in 2001 (because they thought they might be pregnant), were among the 80 thousand who had attended family planning clinics for contraception? Recent research of teenage pregnancies in general practice shows that most teenagers who became pregnant had discussed contraception (71 per cent) in the year before conception, and two-thirds (65 per cent) had been prescribed oral contraception before they became pregnant. Moreover, as this research was based solely on GP records and did not take account of contraceptives provided by family planning clinics, it under-estimates the total provision of contraception to pregnant teenagers.44 So the true rate of contraception use prior to teenage pregnancy is likely to be even higher. Indeed, it is well known that the rate of contraceptive failure among children is high, hence the Government’s campaign to provide emergency contraception. These disturbing figures suggest that while contraceptive based sex education has certainly encouraged children to use contraception it has not prevented them from becoming pregnant.

The age of sexual consent
The Government’s policy of promoting contraception among under-age girls and teaching them how to negotiate ‘safer sex’ needs to be seen in the context of the law on the age of sexual consent. According to the law of the land, based on the Criminal Law Amendment Act 1885, and the Sexual Offences Act 1956, sexual intercourse between a man and a girl under 16 is a serious criminal offence so far as the man is concerned. Parliament enacted these laws for the purpose of protecting young girls from sexual exploitation.

Despite the law on the age of consent, the British Government, in an attempt to reduce the rate of teenage pregnancies, issued a memorandum in 1974 that permitted doctors to prescribe contraceptives to under-age children without the knowledge or consent of their parents.

In 1979 The Working Paper on the Age of Consent in relation to Sexual Offences, produced under the chairmanship of Lord Justice Waller, emphasised the importance of the law in protecting under-age girls. ‘In our opinion, sexually immature girls need protection from sexual intercourse on two grounds. First, when an immature girl has sexual intercourse with a man, her gradual development towards sexual maturity can be affected. She may be introduced prematurely into a world of adult feelings with only an adolescent’s ability to control them. Secondly, an immature choice is not a free one. Immature girls are open to exploitation, particularly by older men, but also by boys of their own age or slightly older, who know what they want and are not deterred by using all kinds of psychological pressure to get their way. We think it is true that most girls are not eager to have sexual intercourse before they reach 16. The present law is, we consider, one factor strengthening their resolve to say “no”.’45

In 1983 Mrs Victoria Gillick sought a High Court declaration that the Government’s memorandum of 1974 was unlawful. Although she eventually lost her case on a split judgement in the House of Lords, over the course of her prolonged legal battle five judges found in her favour, against four who supported the Government. Two judges, in particular, cast considerable doubt on the lawfulness of the Govern-ment’s position. In his ruling Lord Brandon wrote: ‘It is sometimes said that the age of consent for girls is presently 16. This is, however, an inaccurate way of putting the matter, since, if a man has sexual intercourse with a girl under 16 without her consent, the crime which he thereby commits is that of rape. The right way to put the matter is that 16 is the age of a girl below which a man cannot lawfully have sexual intercourse with her. It was open to Parliament in 1956, when the Sexual Offences Act of that year was passed, and it has remained open to Parliament throughout the 29 years which have since elapsed, to pass legislation providing for some lower age than 16, if it thought fit to do so. Parliament has not thought fit to do so…’ In his opinion, providing children with contraceptives is ‘to undermine or circumvent the criminal law which Parliament has enacted’, and this must be contrary to public policy.46

Lord Templeman ruled that an unmarried girl under the age of 16 did not, in his opinion, ‘possess the power in law to decide for herself to practise contraception… Parliament has indicated that an unmarried girl under the age of 16 is not sufficiently mature to be allowed to decide for herself that she will take part in sexual intercourse. Such a girl cannot therefore be regarded as sufficiently mature to be allowed to decide for herself that she will practise contraception for the purpose of frequent or regular or casual sexual intercourse.’47

And so the question arises: is the Government, by encouraging the use of contraception among under-age children, undermining the criminal law? (The Gillick case is discussed in chapter 14.)

The Government is now so confident of its approach that it has introduced a target to reduce the rate of teenage pregnancies by 50 per cent by the year 2010. The main weapons in its armoury are sex education, with its ‘safer sex’ message, and when that fails, emergency contraception. Reading the Government’s guidance we could be forgiven for thinking that this is a new idea. In all its advice and guidance there is no mention of the fact that there has been a major sex education campaign in the UK since the early 1970s. There is not the slightest hint that the contraceptive based sex education of the last three decades may have been a failure. The proposition that promoting contraceptives among young people may be part of the problem is not even considered. In the mind of the Government, the problem is simply that the promotion of contraception has not been vigorous enough, that sex education messages have not been explicit enough and have not started at an early enough age. So after three decades of sex education we are asked to believe the Government’s assertion that the underlying problem is that young people lack accurate knowledge about sex and contraception.

In this book I challenge the Government’s assumption that the answer to the crisis in teenage pregnancy lies in yet more sex education and a yet more vigorous promotion of contraception among young people. I argue that comprehensive sex education is not only ineffective in achieving its stated objective of reducing sexual tragedies, but that it contributes to the problem. There is a better message for young people than that delivered by sex education, and the good news is that young people do not need to rely on contraceptives to avoid becoming pregnant. The so-called ‘moralisers’, so easily dismissed by the sex education lobby, do have something important to say. Because sex education raises profound moral questions, I approach the issue from a biblical perspective. Moreover, as over 70 per cent of the population still regard themselves as Christian, according to the latest census, it is important to examine the teachings of sex education in the light of biblical truth, the foundation of traditional morality in Great Britain. As we shall see, the real effect of sex education, whether by design or default, has been to liberate children from Christian standards that have formed the moral foundation of sexual behaviour in this country for over a thousand years.

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Endnotes
1 Teenage Pregnancy, HMSO, London, June 1999, p4
2 Ibid. p4
3 Ibid. p5
4 BBC News Online, 27 June 2002, Pupils’ contraceptive plan prompts fury
5 The Mail on Sunday, 4 November 2001, ‘The card that lets children as young as 13 get free condoms’, Ian Cross
6 Contraception, Barbara Hastings-Asatourian, Contraception Education Limited, 2001, p7
7 Ibid. p42
8 Ibid. p45
9 Times Educational Supplement, 26 October 2001, Contraception is a game of chance, Nic Barnard
10 BBC News website, 26 October 2001, School sex board game criticised
11 Exeter University website, ‘A Pause For Health’
12 BBC News website, 21 February 2003, Sex lessons ‘go too far’
13 Times Educational Supplement website, taken from Breaking News, 21 February 2003, Under-16s health course ‘should have avoided the mention of oral sex’
14 Times Educational Supplement website, taken from News & opinion, 21 February 2003, The heart of the matter, Lynda Brine
15 Daily Telegraph, 16 March 2002, ‘Tesco gives morning-after pill to teenagers’, Becky Barrow
16 Ananova News website, 22 August 2002, Government supports Sainsbury’s pill move
17 The Sunday Times, 7 January 2001, ‘Under-age girls to be given morning-after pill at school’, Adam Nathan
18 Ibid. Teenage pregnancy, p7
19 Ibid. p17
20 Ibid. p7
21 Ibid. p7
22 Ibid. p7
23 Ibid. p90
24 Ibid. pp40-41
25 Ibid. p95
26 Ibid. p8
27 Why the Government’s Teenage Pregnancy Strategy is destined to fail, Family Education Trust, 2002, p4
28 Ibid. p8
29 Ibid. Teenage Pregnancy, p10
30 Ibid. p10
31 Ibid. p11
32 Sex and Relationship Education Guidance, DfEE, July 2000, Introduction, p3
33 Ibid. p20
34 Ibid. p9
35 Ibid. p5
36 Ibid. p20
37 Ibid. p10
38 Ibid. p4
39 Ibid. p22
40 Ibid. p15
41 Ibid. p18
42 NHS Contraceptive Services, England: 2001-02, bulletin 2002/20, Department of Health, ed. Lesz Lancucki, October 2002
43 Ibid.
44 Dick Churchill et al, Consultation patterns and provision of contraception in general practice before teenage pregnancy: case control study, British Medical Journal, 321, pp486-89
45 Working Paper on the Age of Consent in relation to Sexual Offences, HMSO, June 1979, cited from the article, ‘A Lost Grandeur’ in February 1999 edition of Catholic Medical Quarterly, catholicdoctors website.uk
46 Butterworths LexisNexis Direct, House of Lords, 17 October 1985, Gillick v West Norfolk, pp27-28
47 Ibid. p28

 

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