Professional Documents
Culture Documents
Sexualities
15(5/6) 739757
! The Author(s) 2012
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DOI: 10.1177/1363460712446279
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Abstract
Against a negative background, recent scholarship indicates a socio-cultural and medical
reconceptualisation of consensual BDSM. At a point where consensual BDSM appears
to be on the cusp of a new understanding and the question of full inclusion in the polity
arises, any new legal frustration of its expression may have profound impacts, particularly in terms of citizenship claims. Focusing on the European Court of Human Rights
decision in Pay v UK (2009) concerning the dismissal of a self-identified BDSM probation
officer, this article considers the cases significance for the development of consensual
BDSM as a rights-bearing identity before the law and in relation to questions of sexual
citizenship. Noting how the Court relies on negative and distorted stereotypes of
consensual BDSM, this article further observes how the expulsion of the consensual
BDSM identity from the probation service is rendered necessary to maintain the sexually normative coherence of the polity and, in the context of the Pay case, the civil
institutions that regulate it.
Keywords
Consensual BDSM, European Court of Human Rights, law, Pay v UK, probation service,
sexual citizenship
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Sexualities 15(5/6)
B Thompson, 1994; M Thompson, 1991; Weinberg et al., 1984). Whereas pathological classications of homosexuality have largely been revised, inuential diagnostic and classication manuals such as the World Health Organisations ICD10
and Americas DSM-IV have retained the view of consensual sadomasochism as a
mental/behavioural disorder which poorly reects the critical distinctions between
consensual and non-consensual practice (Beckmann, 2004, 2009; Langdridge, 2006;
Reiersl and Skeid, 2006; Sagarin et al., 2009; Taylor and Ussher, 2001; B
Thompson, 1994; M Thompson 1991; cf. Krueger, 2009). Yet against this background, a growing body of work argues that consensual BDSM ought to be seen
more positively. Such work has gained crucial momentum, describing an increasingly public manifestation and politicisation of consensual BDSM where full inclusion in the polity is a realistic consideration. Scholarship on sexual identity
narratives bears witness to the rising prole and circulation of consensual BDSM
stories and their central role in the social construction of the consensual BDSM-self,
a scripting which now appears to be coming into its own (Barker and Langdridge,
2009; Chaline 2010; Langdridge, 2006; Langdridge and Butt, 2004). In sum, as
Langdridge and Butt (2004: 35) have asserted, the time for consensual BDSM to
be heard has now come.
At this critical juncture, where consensual BDSM appears to be on the cusp of a
new understanding, it is arguable that any new legal frustration of its expression
may have profound impacts, particularly in terms of citizenship claims. As
Langdridge (2006: 385) has alluded to in his analysis of BDSM citizenship, strategies for inclusion must contain consideration of moment as well as momentum.
Taking the question of consensual BDSM citizenship seriously, I suggest that
whilst there is a degree of momentum here in that the conditions of possibility
for BDSM citizenship look increasingly favourable, legal developments at this
moment of reframing require careful consideration. Although the role of the criminal law in the negative positioning of consensual BDSM has been well documented, recent litigation in the eld of employment law culminating in the
European Court of Human Rights (ECHR) decision of Pay v UK2 also demands
scrutiny. Given that the social, cultural and medical construction of consensual
BDSM as well as the conditions of citizenship exist within the context of a regulatory framework, any development in the legal (and resultant institutional) control
of consensual BDSM needs analysis. In this article, after outlining some key shifts
in the socio-cultural and medical representations of consensual BDSM, I consider
law as a key site of contest in the construction of the consensual BDSM-self,
focusing on the recent case of Pay v UK. I seek to identify the wider signicance
of the case in relation to questions of citizenship with specic emphasis on issues of
visibility, acknowledgement and the ability to render civic service. I argue that in
Pay negative and distorted stereotypes of consensual BDSM are invoked to justify
its expulsion; an expulsion which serves to maintain the sexually normative coherence of the polity and, in the context of the Pay case, the civil institutions that
regulate it. The term sexually normative may be taken to mean where sexuality is
reective of or conforming to heteronormative structures typically characterised by
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binary, gendered and hierarchical ideals of appropriate sexual containment, propriety and boundedness, and in this respect, sexual normativity should be understood to include homosexuality and lesbian sexuality that also mirrors these
structures and ideals (see further Hubbard, 2001).
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critical to its understanding, as are questions of consent, privacy and the criminal
law, developments in the eld of employment law as seen in the case of Pay v UK in
relation to consensual BDSM in its own right signal a site of renewed and
expanded legal engagement. The litigation concerned a man employed by the
Lancashire Probation Services (LPS) whose work involved the treatment of sex
oenders. It was never in dispute that he was well regarded by his employer in
respect of his work; rather, the contention lay with his extra-curricular activities.
Following his employers inquiry (directed to all employees) as to whether or not
they were Freemasons, the employee responded in the negative, but disclosed that
he was a member of a number of other organisations, including The House of
Roissy (later to become Roissy Workshops Ltd of which the employee was a
director). The employee had also disclosed that his hobbies included a circus-type
re act, which was even performed on one occasion for a probation service open
day, with no apparent controversy (Pay, 2004: 193).
However, a few months after the questionnaire was circulated, Lancashire
police received an anonymous fax indicating that Roissy advertised online as a
manufacturer and supplier of BDSM goods and services. The fax included a
photograph of the applicant in a mask, accompanied by two semi-clothed
women. The police took no action, but referred the matter to the LPS, who
conducted an investigation. The LPS established that Roissy was indeed registered at the applicants address, supplied BDSM goods and services, and that its
website was linked to a number of BDSM websites, one of which included photographs of the applicant engaged with instruments of re with semi-clothed
women (Pay [2004]: 193). There were also photographs of the applicant engaging
in performances involving bondage and domination. Associated text suggested
that the acts had taken place at a local private members club, involving male
domination over submissive women.
The LPS immediately suspended the applicant on full pay. It argued that his
sexual activities, although not criminal, might be incompatible with his role as a
probation ocer and bring LPS into disrepute. Although the applicant admitted
that he was involved in performance shows at fetish and hedonist clubs, and had
already stated his involvement with Roissy, he argued that he had never authorised
the photographs and had asked the website to remove them, which they had since
done. Upon review, although weighing in the balance the ECHR rights of respect
to private and family life (Article 8), freedom of expression (Article 10) and the 17
years of good service rendered by the applicant, the LPS still concluded that the
applicant had acted in a manner incompatible with his work and was dismissed. In
both the Employment Tribunal (ET) and Employment Appeal Tribunal (EAT),
the claims under Articles 8 and 10 were rejected. The EAT felt that the response
of the employer was proportionate and noted the nding of fact made by the ET
that the applicant had consistently refused to accept the employers view as
reasonable and that he had been reluctant to sever his connection with Roissy.
Given these facts, and the employers views, alternative employment within the
organisation was not feasible.
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But the loss of condence is something never actualised, rather a spectre lying at
the heart of the case such that the language of risk becomes self-justifying. The
conclusion of unacceptable risk appears to be directly at odds with the Courts own
consideration that society may be increasingly tolerant and broadminded, and in
contradiction to the mounting body of evidence that suggests a more positive
reception for consensual BDSM. There is no real debate as to precisely why the
applicants BDSM identity is at odds with his role as a probation ocer working
with sex oenders, which is particularly curious given the evidence accepted by the
Court, which attests to his considerable abilities in this role. This lack of discussion
is worrying, suggesting an assertion based on a common sense argument that is
self-justifying and as such requires no further explanation or comment. As such,
the argument could be broadly applied to any public sector of employment in order
to dismiss those who appear not to t in to a model of normative sexuality. The
rationale that the probation services work with sex oenders might be undermined
both in the public eye and in the estimation of sex oenders themselves eectively
conates consensual BDSM and explicitly non-consensual sex oences, a move
which compounds the traditional pathological model. Whatever risk may arise in
the context of the employers reputation in Pay is implicit, unspoken and relying on
sedimented stereotypes of consensual BDSM. Whilst there is visibility in Pay it is a
paradoxical visibility, erased through its very emergence, and acknowledgement, in
the sense of the legal recognition of the authentic BDMS self actively constructed and publicly apparent as valid and viable thus worthy of recognition as
equal is lacking.
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Bottomley and Moore, 2007), a role central to the probation service. As noted by
the EAT:
The modern probation service is a law enforcement agency at the heart of the criminal
justice system. It aims to see that oenders receive proper punishment for their oending by the way they are supervised in the community. It works for their eective
rehabilitation so they are less likely to oend in the future . . . Its responsibilities
include the delivery of eective programmes for supervising oenders safely in the
community and upholding the interests of victims of crime. (Pay, 2004: 192)
The probation service can be seen in this respect to serve a double function in
terms of citizenship. Firstly, the right to render civic service can be seen as a key
factor in the construction of the active and engaged citizen, thus through being a
probation ocer one actively contributes by helping to secure the health and wellbeing of the polity. Secondly, it is through civic service that oenders may be
redeemed, community service orders prompting their re-engagement with the
polity to repair their alienation. In that the body politic is open to infection, the
risk in this context can be understood as that posed by sexually deviant criminal
elements, the sex-oender (in particular the paedophile) arguably being seen as the
current apex of anti-citizenship. In this respect, the probation service is an important location of the construction and maintenance of a secure, healthy and sexually
normative polity. Owing to public concern, sex oenders in particular are subject to
explicitly heightened scrutiny in relation to probation, and must be overtly managed (HMI Probation and HMI Constabulary, 2010). But whereas the criminal law
can be seen to demarcate the distinction between self and perverse other those
whose (typically non-consensual) sexual deviancy is registered by the law such as
the rapist and the paedophile, the probation service, as a law enforcement agency,
further reinforces this distinction as the very service dedicated to the successful
monitoring, socialisation and rehabilitation of oenders; socialisation and rehabilitation in particular being redemptive processes that explicitly speak of the active
transformation from deviant to one who is, in the common parlance, going
straight, whereas monitoring and managerialism speak to the (unredeemed) deviants continued separation and otherness. In the current context, probation can be
contextualised within the conditions of a new penology, where transitions are seen
from rehabilitation and treatment to a language of probability and risk and from
ideals and values associated with people, towards managerial, technocratic and
bureaucratic procedures (P Whitehead, 2007: 46). As part of the new managerialism that can be seen to pervade many public services, non-consensual conditions of domination are produced (see further Beckmann and Cooper, 2005),
where a chronically under-resourced probation service (BBC, 2008, 2009;
McKnight, 2009; Penrose, 2009; P Whitehead, 2007, 2010; T Whitehead, 2010)
becomes increasingly mired in neo-liberal managerialism (P Whitehead, 2007,
2010) and framed by a dogmatic approach, based upon penal populism and constant restructuring (McKnight, 2009). P Whitehead notes that the very vocabulary
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Gatekeeper to successful re-entry into civilised society and monitor of identied threats within, the probation service is arguably a key site of brokerage,
complicit in the construction and policing of normative sexual citizenship. Thus
the probation service, which regulates the sexually deviant, must not be found to
be deviant itself. The inaccurate juridical and institutional conation of consensual BDSM with non-consensual sex oending in Pay thus leads the courts to
endorse the conclusion that consensual BDSM is threatening to the probation
service in its entirety: it was agreed that alternative employment would not be an
option given the conclusion that his activities had been found to be incompatible
with the role of any probation ocer (Pay, 2009: 16, my emphasis). But consensual BDSM explicitly plays on the subversion of juridical discipline and punishment, revealing the latter in itself to be inherently sadomasochistic (McClintock,
1993). Tacit acknowledgement of this may be seen to underlie the judgment: the
equipment for sale and for hire included a dungeon which is, of course, a prison
cell (Pay, (2004: 196, my emphasis). Whereas common sense understandings of
power may claim ignorance of (and thus mask) its dynamics and asymmetries,
consensual BDSM facilitates its explicit recognition and through this, its deconstruction (Beckmann, 2009). Thus the applicants BDSM sexuality becomes a
highly resistant and challenging act, one which actively resignies the ideality
of the norm (Loizidou, 2007: 155) a move which not only reveals the performativity of the BDSM identity as well as that of the normative identity, but also
the inherent performativity of institutions which construct and maintain such
norms (see further Beckmann, 2009; Butler, 1990; Chancer, 1992). Rendered visible, the presence of the consensual BDSM identity in the probation service
engenders a profound moment of crisis as such norms are revealed to be unstable
and contingent. Thus its expulsion becomes inevitable in order to maintain the
sexually normative character of the probation service, and with it the polity.
However, such institutional and juridical censure of consensual BDSM in itself
eectively serves to mask not only the institutionalisation of the conditions of
non-consensual domination and control in the probation service but the wider
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Conclusion
It may seem that the position sought by the litigant in Pay is paradoxical, in that
the claim to a private life may be seen as standing in contradiction to the right of
public articulation. Yet this very paradox lies at the heart of debates on sexual
citizenship: the tension between transgression and inclusion, dissidence and
accession to the dominant legal and political order (Grabham, 2007: 37; see
also Bell, 1995; Bell and Binnie, 2000; Hubbard, 2001; Richardson, 2000;
Weeks, 1998). In relation to consensual BDSM, Bell (1995: 147) has noted that
the citizen pervert who does not conform to normative sexual citizenship is
exactly on the slash of the public/private split, irreducible to either domain
and that laws eruptions into the private begin a process of reducing or even
erasing the private as a site of pleasure, rendering pleasure a public and by that
political issue. In that the sexual citizen negotiates the public/private sphere
paradoxically, as the security of private space is claimed through an emergence
into publicity, Bell and Binnie warn against a merely tactical emergence which
only serves to enable the claim to privacy the proper home of the sexual
citizen (2000: 4). On such a model, a politics of assimilation is invoked where a
rights-based strategy forces the sexual citizen into a modality that is privatised,
deradicalized, de-eroticised and conned in all senses of the word (Bell and
Binnie 2000: 3, their emphasis). As they see it, the challenge for a project of
sexual citizenship is therefore to negotiate a model of citizenship (and citizen)
that does not reproduce the exclusion of dierence and dissidence. Richardson
also warns against a citizenship whereby the public/private divide works to
underscore a liberal model of sexual citizenship . . . based on politics of tolerance
and assimilation (2000: 110; see also Grabham, 2000). Although for some, the
very allure of consensual BDSM may well lie in its transgressive status, and thus
questioning the desirability of an entry into full citizenship, commentators such
as Stychin (2001) have suggested that a concentration on more than one strategy
is necessary to fully critique citizenship itself. Stychin considers that plural spheres
of engagement and development are necessary:
[T]he elaboration of identity politics . . . [requires] both separate spaces for the development of a shared subculture and an ongoing focus on the integration of groups into
broader social forms. This provides a useful way of troubling the dichotomy between
social assimilation and separatism . . . between normalization and transgression . . . [n]either side . . . can be renounced, for both become moments which are of
ongoing importance for the possibility of civic inclusion. (2001: 288)
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Thus citizenship always has the potential to be rearticulated (Stychin 2001: 289,
original emphasis) and whilst consensual BDSM has been theorised as a limit
identity for citizenship, this very marginality need not necessarily be reduced to a
choice between assimilation and transgression. As Langdridge (2006: 387) argues,
SM practitioners may be too sexual, too fragmented and/or too transgressive for
citizenship as it now stands, but through their strangeness the limits of citizenship
become apparent and the need for radical reconceptualization obvious. This dialectic is, in itself, the very discourse of citizenship.
In relation to these problematics, it can be argued that the emergence into
publicity in Pay is not merely tactical and thus transient, in that it represents a
demand to be self-denitional and expressive and fully acknowledged by the state
and its institutions as such and not as a precursor to disappearance in the private
sphere. The claim in Pay is not a demand for consensual BDSM to be tolerated
only out of sight, nor is it one predicated on access to an already normatively
constructed legal institution such as marriage, rather it challenges the existing legal
mode of citizenship by demanding inclusion on its own terms. Thus whilst on
the surface the claim to a private life may be seen as standing in contradiction to
the right of public articulation, the claims can be read in terms of the desire for the
articulation of the BDSM self to be free from state interference, hence conceptualised as a desire for a private life, but performed as communicative, democratic and
equal, requiring a specically public context of performance such that it is not
socially and legally closeted, repressed or otherwise subjugated. The spatial dynamics of the would-be sexual citizen in Pay are uid as Hubbard (2001: 67) has
indicated: publicity and privacy co-join dierently in dierent places, and it is in
sites that are imagined as not solely public or solely private that new identities will
emerge. Yet the potential space in which this citizen might emerge is collapsed by
the construction of citizenship as marked by a strict re-inscription of the public/
private divide, in that either the applicant may be a public servant as a probation
ocer, but by denition this cannot be one who is self-identied with consensual
BDSM; or a private individual so identied who by virtue of this very self-denition may not be an active citizen engaged in the public service of probation. Whilst
state recognition is not, as Phelan states (2001: 6), the sole arbiter of citizenship,
Pay reminds us that the eects of the law can be extensive and cannot necessarily
be seen in isolation from other institutions and modes that constitute the engaged
and politicised citizen. Indeed, as Phelan herself also notes (2001: 18), [a]cknowledgement consists both in legal inclusion and formal rights and in active acknowledgement of individuals and groups as part of the polity. Although it could be
argued that there could be a danger of overinvesting in the power of the law as an
arbiter of citizenship, its signicance and inuence in relation to other vectors of
citizenship soon becomes apparent when the prospective sexual citizen, as in Pay,
faces the prospect of being denied the right to articulate their chosen identity, to a
livelihood in their chosen profession, to civic service and to legitimacy and recognition; a prospect that is surely antithetical to even the most reective and inclusive
model of sexual citizenship.
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Acknowledgments
I wish to thank the anonymous reviewers for their close reading and helpful suggestions.
Thanks also to Suzanne Ost, David Sugarman, Madeleine Chatterjee and Christiana
Markou for their discussion of previous drafts. Previous versions of this article were
presented at the Socio-Legal Studies Association Conference, UWE Bristol 2010, and
the University of Lancaster Centre for Gender and Womens Studies Research Day
2010. I thank the audiences at both events for their valuable feedback. All errors are
my own.
Notes
1. I use the term BDSM to describe sexual identities allied to bondage, domination and
sadomasochism in the non-medicalised (i.e. non-pathologised) sense, that is, where
power differentials are sexualised and/or where intense sensations are exchanged,
and, importantly, where parties are consenting. This acknowledges that the term
BDSM is increasingly used by those who self-identify as such, in preference to the
term SM, as it is felt that the latter has pathological associations and places too
much emphasis on the pain aspect of such practices. Thus BDSM is descriptive of a
broader range of practices, a non-pathological term, and a self-definition arising from
communities themselves (Bauer, 2008). When citing case reports, as with academic
commentators, I have chosen to retain their original terminology, using whichever
term or variant appears.
2. For a list of cases and statutes, please see Appendix.
3. See e.g. bdsmrights.com (bdsmrights.com, n.d.)
4. See revisef65.org (n.d.: postings of 11 November 2011); unfettered.co.uk (20002008). See
also backlash-uk.org.uk (2012).
References
backlash-uk.org (20052012) Available at: http://www.backlash-uk.org.uk/index.html/
(accessed 9 July 2012)
Barker M and Langdridge D (2009) Silencing accounts of silenced sexualities. In: RyanFlood R and Gill R (eds) Secrecy and Silence in the Research Process: Feminist
Reflections. Abingdon: Routledge, pp. 126.
Barker M, Gupta C and Iantaffi A (1997) The power of play: The potentials and pitfalls in
healing narratives of BDSM. In: Langdridge D and Barker M (eds) Safe, Sane and
Consensual: Contemporary Perspectives on Sadomasochism. Basingstoke: Palgrave
Macmillan, pp. 197216.
Bastian D (2002) Chainmale. Los Angeles, CA: Daedalus.
Bauer R (2007) Playgrounds and new territories the potential of BDSM practices to
queer genders. In: Langdridge D and Barker M (eds) Safe, Sane and Consensual:
Contemporary Perspectives on Sadomasochism. Basingstoke: Palgrave Macmillan,
pp. 117196.
Bauer R (2008) Transgressive and transformative gendered sexual practices and white
privileges: The case of the dyke/trans BDSM communities. Womens Studies Quarterly
36(3/4): 233253.
BBC (2008) Probation service faces crisis, 24 April. Available at: http://news.bbc.co.uk/1/
hi/uk/7362879.stm (accessed 5 July 2010).
754
Sexualities 15(5/6)
Chatterjee
755
Fraser N (1992) Rethinking the public sphere: A contribution to the critique of actually
existing democracy. In: Calhoun C (ed.) Habermas and the Public Sphere. Cambridge:
MIT Press, pp. 109142.
Grabham E (2007) Citizen bodies, intersex citizenship. Sexualities 10(1): 2948.
Henkin W (2007) Some beneficial aspects of exploring personas and role play in the
BDSM context. In: Langdridge D and Barker M (eds) Safe, Sane and Consensual:
Contemporary Perspectives on Sadomasochism. Basingstoke: Palgrave Macmillan,
pp. 229240.
HMI Probation and HMI Constabulary (2010) Restriction and Rehabilitation: Getting the
Right Mix. Criminal Justice Joint Inspection Report.
Hubbard P (2001) Sex zones: Intimacy, citizenship and public space. Sexualities 4(1): 5171.
Krueger R (2010) The DSM diagnostic criteria for sexual sadism. Archives of Sexual
Behaviour 39(2): 325345.
Langdridge D (2006) Voices from the margins: Sadomasochism and sexual citizenship.
Citizenship Studies 10(4): 373389.
Langdridge D and Barker M (eds) (2007) Safe Sane and Consensual: Contemporary
Perspectives on Sadomasochism. Basingstoke: Palgrave Macmillan.
Langdridge D and Butt T (2004) A hermeneutic phenomenological investigation of the
construction of sadomasochistic identities. Sexualities 7(1): 3153.
Loizidou E (2007) Judith Butler: Ethics, Politics, Law. London: GlassHouse Cavendish.
Mantouvalou V (2008) Human rights and unfair dismissal: Private acts in public spaces.
Modern Law Review 71(6): 912939.
Mantouvalou V and Collins H (2009) Private life and dismissal. Industrial Law Journal
38(1): 133138.
McClintock (1993) Maid to order: Commercial S/M and gender power. In: Church-Gibson
C and Gibson R (eds) Dirty Looks: Women Pornography Power. London: British Film
Institute, pp. 207231.
McKnight J (2009) Speaking up for probation. The Howard Journal 48(4): 327343.
Monceri F (n.d.) Sadomasochism. Deconstructing sexual identity through power. Undated/
unpaginated, paper. Available from: http://www.inter-disciplinary.net/ci/transformations/sexualities/s5/monceri%20paper.pdf (accessed 9 July 2012).
Moore A (2009) The invention of sadism? The limits of neologisms in the history of sexuality. Sexualities 12(4): 486502.
Moser C and Kleinplatz P (2007) Themes of SM expression. In: Langdridge D and Barker
M (eds) Safe, Sane and Consensual: Contemporary Perspectives on Sadomasochism.
Basingstoke: Palgrave Macmillan, pp. 3554.
Norman S (1991) I am the Leatherfaerie Shaman. In: Thompson M (ed.) Leatherfolk. Los
Angeles, CA: Alyson Publications, pp. 276283.
Penrose J (2009) 34m probation service job crisis, The Sunday Mirror, 23 August. Available
at:
http://www.mirror.co.uk/news/top-stories/2009/08/23/34m-probation-service-jobcrisis-115875-21618686/ (accessed 5 July 2012).
Phelan S (2001) Sexual Strangers: Gays, Lesbians, and Dilemmas of Citizenship.
Philadelphia, PA: Temple University Press.
Rambukkana N (2007) Taking the leather out of leathersex. In: ORiordan K and Phillips D
(eds) Queer Online. Oxford: Peter Lang, pp. 6780.
Reiersl O and Skeid S (2006) The ICD diagnoses of fetishism and sadomasochism. Journal
of Homosexuality 50(2/3): 243262.
756
Sexualities 15(5/6)
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Appendix
Cases/statutes
Criminal Justice and Immigration Act 2008
Laskey, Jaggard and Brown v UK (1997) 24 EHRR 39
Pay v Lancashire Probation Services (EAT) (2004) ICR 187
Pay v UK (2009) 48 EHRR SE2
R v Brown (1994) 1 AC 212
R v Wilson (1997) QB 47
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