Response of the Equality and Human
Rights Commission to the Joint
Committee on Human Rights inquiry into
violence against women and girls (VAWG)
MARCH 2014
Contact details:
Rachel Zaltzman - Programme Head, Human Rights and Respect
Tel: 0207 832 7843
Rachel.Zaltzman@equalityhumanrights.com
1
1. Background
The Equality and Human Rights Commission (the Commission) is one of the UK’s
three national human rights institutions (NHRI) with “A” status accreditation at the
United Nations (UN). Our role is to promote and enforce the laws that protect rights
to fairness, dignity and respect. The Scottish Human Rights Commission has
jurisdiction with respect to matters that are devolved to the Scottish Parliament. The
Commission’s remit does not extend to Northern Ireland, which is covered by the
Northern Irish Human Rights Commission. Together, the UK’s three NHRIs
encourage, monitor and report on the United Kingdom’s ratification of and
compliance with international human rights instruments.
2. Purpose and Scope
We welcome the Joint Committee on Human Rights’ (JCHR) inquiry into violence
against women and girls (VAWG) and its framing within the Council of Europe’s
Convention on Preventing and Combating Violence Against Women and Domestic
Violence1 (the Istanbul Convention) and the UN Convention on the Elimination of
Discrimination Against Women2 (CEDAW). This is a timely intervention as the UK
Government has signed but not yet ratified the Istanbul Convention. We are also
approaching the one year anniversary of the UK’s most recent examination by the
UN’s CEDAW Committee in July 20133 and the mid-term review of the UN Human
Rights Council’s Universal Periodic Review of the UK.4
The Commission’s submission will focus on two themes:
 The extent to which UK law, policy and practice are compliant with the
Istanbul Convention and what more needs to be done to enable the UK to
ratify the Istanbul Convention and ensure its effective implementation; and
 The VAWG issues the Commission pursued through its shadow report to the
CEDAW Committee5, including our analysis of actions required to improve the
UK’s compliance with the Committee’s General Recommendation 19.6
1
Opened for signature in May 2011, the Istanbul Convention is the first legally binding instrument in
Europe to prevent and combat violence against women and domestic violence.
http://www.coe.int/t/dghl/standardsetting/conventionviolence/convention/Convention%20210%20English.pdf
2
Adopted in 1979 by the UN General Assembly, CEDAW is often described as an international bill of
rights for women. Consisting of a preamble and 30 articles, it defines what constitutes discrimination
against women and sets up an agenda for national action to end such discrimination.
http://www.un.org/womenwatch/daw/cedaw/text/econvention.htm
3
The Concluding observations on the seventh periodic report of the United Kingdom of Great Britain
and Northern Ireland were published on 30 July 2014.
http://tbinternet.ohchr.org/_layouts/treatybodyexternal/Download.aspx?symbolno=CEDAW%2fC%2fG
BR%2fCO%2f7&Lang=en
4
The UNHRC published its report of the Universal Periodic Review of the UK in May 2012. It included
132 recommendations. The mid-term review in autumn 2014 will review the progress the UK has
made in implementing them. http://daccessods.un.org/access.nsf/Get?Open&DS=A/HRC/21/9&Lang=E
5
http://www.equalityhumanrights.com/uploaded_files/humanrights/CEDAW/submission_7th_periodic_r
eport_of_uk_to_cedaw_june_2013.pdf
6
General Recommendation No. 19 was agreed at the CEDAW Committee’s 11th session in 1992 http://www.un.org/womenwatch/daw/cedaw/recommendations/recomm.htm
2
Our submission is structured, broadly, according to the obligations on the State
within the Istanbul Convention to:
 prevent violence against women and girls (Chapter III);
 protect and support victims (Chapter IV); and
 investigate and prosecute perpetrators of violence against women and girls
(Chapter VI).
The Commission recently submitted evidence7 to the Home Affairs Select
Committee’s inquiry into Female Genital Mutilation, which should be referred to for
our detailed opinion on that issue.
3. Summary
While we welcome the UK Government’s national strategy8 for England and Wales,
we note the potential risks to effective implementation implied by the lack of a central
budget and emphasis on local decision-making. In this context, we question the UK
Government’s ability to discharge its responsibility to secure the safety of women
across Great Britain as a human right under CEDAW. We welcome the initiatives of
the Welsh and Scottish Governments to develop their own VAWG strategies,9 and
the Welsh Government’s intention to bring forward legislation to help tackle VAWG in
Wales.10
The Commission notes the UK Government has signed but not yet ratified the
Istanbul Convention. The UN Human Rights Council called for ratification in its 2012
Universal Periodic Review of the UK11 and implementation would require improved
coordination of work to prevent VAWG and legal protections, and that support
services be adequately funded. It would also improve the UK’s compliance with
CEDAW, specifically General Recommendation 19 (GR19).
Our analysis concludes most of the Istanbul Convention obligations are, where
necessary, implemented through British legislation. However potential legislative
non-compliance remains, including:


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a prohibition on simulated rape pornography (Article 12) – to be addressed
through the Criminal Justice and Courts Bill 2013-14.
introducing more robust requirements in relation to the display of highlysexualised images of women in 'lads magazines' in shops (Article 14)
http://www.parliament.uk/documents/commons-committees/homeaffairs/FGM%20written%20evidence.pdf – page 227
8 In 2013, the UK Government published an updated action plan to support implementation of its
VAWG Strategy “A Call to End Violence Against Women and Girls” https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/181088/vawg-actionplan-2013.pdf
9 In 2010, the Welsh Government published “The Right to be Safe” http://wales.gov.uk/topics/people-andcommunities/safety/domesticabuse/publications/besafe/?lang=en . The Scottish Government is
developing its own VAWG strategy, which is likely to be published in summer 2014 http://www.scotland.gov.uk/Topics/People/Equality/violence-women/strategydocuments
10
In November 2012 the Welsh Government consulted on legislation to end VAWG http://wales.gov.uk/consultations/people-and-communities/vawwhitepaper/?lang=en
11
http://daccess-ods.un.org/access.nsf/Get?Open&DS=A/HRC/21/9&Lang=E – recommendations 29
and 70.
3





a criminal offence of intentionally seriously impairing a person’s psychological
integrity through coercion or threats (Article 33)
the criminalisation of forced marriage (Article 37) – to be addressed through the
Anti-Social Behaviour, Crime and Policing Bill 2013-14
the extension of extra-territorial criminal jurisdiction (Article 44)
the extension of Multi Agency Public Protection Arrangements (MAPPA)
categories 1 and 2 to cover offences committed abroad (Article 51)
an amendment to the Immigration Rules to reflect the relevance of non-domestic
VAWG (Article 59)
Moreover, issues primarily to do with implementation mean the UK may fall short of
full compliance with other Istanbul Convention obligations, including:








the establishment of a full time coordinating body (Article 10)
improvements to data collection and analysis (Article 11)
including personal, social and health education in the national curriculum for
schoolchildren (Article 14)
addressing systematic problems in the training of professionals (Article 15)
allowing third party complaints about press representation of women (Article 17)
providing sufficient financial and legal support and refuge to victims of VAWG
(Article 20)
consistent implementation of the law on consent (Article 36)
shortcomings in the gender sensitivity of the asylum system (Article 60)
4. Prevention
a. The establishment of a specific, full time coordinating body, underpinned
by a robust national strategy and action plan with a dedicated budget
(Article 10). Implementation of the UK Government’s 2013 VAWG Action Plan is
overseen by an Inter-Ministerial Group (IMG), chaired by the Home Secretary.
The ability of the IMG to fulfil the requirements of Article 10 is constrained by:
 Its remit is delineated by the VAWG Action Plan, rather than the Istanbul
Convention, meaning some obligations are excluded, for example the data
requirements of Article 11. The Action Plan also only covers England and
Wales.
 Its membership is relatively high level and does not appear to have a
robust support structure.
 It only meets quarterly, so is unlikely to dedicate the time and resources
required to meet the full range of obligations envisaged by Article 10.
Its emphasis on local autonomy and accountability for decision-making means
the IMG is unlikely to meet the Article 10 requirements for national coordination.
The role of local government is important, but should be secondary to the
monitoring and coordination provided by the UK Government in discharging its
human rights responsibilities. Similarly, while we note the Welsh and Scottish
Governments developing their own VAWG strategies, and proposed VAWG Bill in
Wales that places an emphasis on improving leadership in Wales, there remains
a strong argument for a UK-wide, coordinating body to fulfill the Article 10
functions.
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b. Improvements to data collection and analysis (Article 11) – while some
relevant data is currently collected and analysed, it tends to be as part of a wider
analysis of violent crime, rather than specifically to assess the prevalence of
VAWG. For example, the Office of National Statistics Crime Statistics for England
and Wales merges data on FGM with data on poisoning.12 There is no obvious
connection between the two, and the effect may mask the true reporting and
prosecution levels for FGM. There are also gaps in the data that’s collected. For
example, while there is a separate recording category for trafficking for sexual
exploitation, there are not separate categories for:
 Sex for payment with a threatened, coerced, forced or deceived person
(s.53A of the Sexual Offences Act 2003).
 Trafficking for labour exploitation (s.4 of the Asylum and Immigration
(Treatment of Claimants) Act 2004).
 Forced Labour (s.71 of the Coroners and Justice Act 2009).
We note the UK Government consulted on the questions on intimate violence for
the 2012 Crime Survey for England and Wales13 and could run a similar exercise
to ensure all relevant data is identified and appropriately collated to meet the
specific requirements of Article 11(1)(a)/Article 11(2).
The research proposals in the UK Government’s VAWG Action Plan14 are not
sufficient to satisfy Article 11(1)(b) or Article 24(c) of GR19, through
understanding the root causes and effects of VAWG, incidences, conviction
rates, and efficacy of measures taken to implement the Istanbul Convention and
CEDAW.
c. A prohibition on simulated rape pornography (Article 12) – Articles 11-12 of
GR19 note that the ready availability of pornography, especially to young men,
contributes to “the depiction and other commercial exploitation of women as
sexual objects, rather than individuals. This in turn contributes to gender-based
violence.” However there are some flaws in the criminal law and its enforcement
that constitute non-compliance with the general obligations under Article 12. For
example, while it would be a crime under s63 of the Criminal Justice and
Immigration Act 2008 for a UK based person to publish simulated rape
pornography, there is currently no adequate prohibition on the possession of
pornography depicting VAWG. Clause 1 6 of the Criminal Justice and Courts Bill
2013-14 will close this loophole by extending s63 to cover depictions of rape and
other non-consensual sexual penetration.
d. Including personal, social and health education (PSHE), including
education on relationships, in the national curriculum for schoolchildren in
England (Article 14) – we are concerned the UK Government does not support
inclusion of PSHE in the mandatory subjects on the national curriculum for school
children in England within the Children and Families Bill. It is in PSHE classes
that children can be taught about many of the subjects envisaged under Article
14. In this context, we welcome that the Welsh Government’s proposed Bill
12
Latest ONS Crime Statistics were published in 2012 - http://www.ons.gov.uk/ons/rel/crimestats/crime-statistics/period-ending-june-2012/index.html - Appendix Table A4, offence category 8K.
13
http://www.crimesurvey.co.uk/
14
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/181088/vawg-actionplan-2013.pdf p.54
5
includes a commitment to ensure education on “healthy relationships” is delivered
in all schools.
The UK Government could further promote respect for women by the media, and
in cultural and leisure facilities to help address the objectification of women and
the sexualisation of girls, consistent with Article 24(d) of GR19. The CEDAW
Committee has highlighted the need for these public awareness campaigns to
target black and ethnic minority women.15
We note the Welsh Government’s Bill’s proposal to place a duty on public sector
employers to have a workplace policy for VAW.16 The Commission in Wales has
worked with employers to promote the need for workplace policies that tackle
VAW.17 This good practice could be extended across the UK.
e. More robust requirements for the display of highly-sexualised images of
women in “lads magazines” in shops (Article 14) – there is poor uptake by
media outlets of the guidelines on displaying magazines containing sexualised
images of women in a way that means children would not be able to see them. It
would be in accordance with Article 14 for the UK Government to introduce more
robust requirements for the display of sexualised images of women. One option
would be to make the guidelines mandatory rather than optional, consistent with
the findings of the Bailey Review.18
f. Addressing systematic problems in the training of professionals (Article 15)
– despite the apparent compliance with the training obligations in Article 15, in
practice, some training for professionals seems to be inadequate, as evidenced
by the number of cases where a complaint is not dealt with properly:
 HMIC reported19 on Essex Police’s approach to investigating domestic abuse
with many of the critical findings and recommendations appearing to stem
from deficiencies in training.
 The handling of certain cases by, for example, the Crown Prosecution Service
(CPS), has raised questions over the effectiveness of training even where
strong VAWG policies are in place (see the Stern Review20 for examples in
England and Wales).
One way to address these deficiencies would be to establish a national public
inquiry to consider the failings that have been prevalent to date and how best to
resolve them.
15
http://tbinternet.ohchr.org/_layouts/treatybodyexternal/Download.aspx?symbolno=CEDAW%2fC%2f
GBR%2fCO%2f7&Lang=en – para. 35.
16
http://wales.gov.uk/consultations/people-and-communities/vawwhitepaper/?lang=en
17
http://www.equalityhumanrights.com/wales/past-projects/your-business-workplace-policies-ondomestic-abuse-and-mental-health/domestic-abuse-is-your-business/
18
The Bailey Review of the Commercialisation and Sexualisation of Childhood: Letting Children be
Children Progress Report was published in 2013 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/203333/Bailey_Review
_Progress_Report.pdf - p11-12.
19 HMIC, 2013 http://www.hmic.gov.uk/publication/essex-polices-approach-to-managing-cases-ofdomestic-abuse/
20 Baroness Vivien Stern CBE’s Independent Review into how Rape Complaints are Handled by
Public Authorities in England and Wales was published in March 2010 http://webarchive.nationalarchives.gov.uk/20110608160754/http:/www.equalities.gov.uk/PDF/Stern_R
eview_acc_FINAL.pdf
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g. Allowing third party complaints about press representation of women
(Article 17) – the Leveson Inquiry21 received evidence from a number of
women’s organisations expressing concern about the absence of a clear
procedure for the Press Complaints Commission to receive and adjudicate upon
third party complaints, meaning there is little opportunity to obtain redress where
there is not an identifiable ‘victim’ who is prepared to pursue a complaint on her
own behalf. To give proper effect to Article 17(1), the press regulation system
must permit complaints by non-governmental organisations and interest groups,
as well as by individual women.
5. Protection and Support
a. Providing sufficient financial and legal support and refuge to victims of
VAWG (Article 20) – The UK Government’s Action Plan may not reflect the full
requirements of Article 20 to provide financial support to victims of VAWG. For
example, there is limited analysis of the impact of the Welfare Reform Act 2012.22
While the Action Plan suggests the Universal Credit system will not negatively
affect domestic violence victims, the UK Government ought to make provision for
a full review of its impact, in practice, on victims of VAWG to support this
assertion.
While there is a network of women’s shelters across the UK, largely run by the
third sector, they often struggle to sustain adequate funding and meet demand.
Coverage can be patchy, especially in rural areas. Women’s Aid Scotland reports
it has to turn away one in three women.23 Women can be housed in hostel
accommodation that may be mixed sex and can increase exposure drugs,
alcohol, violence and predatory behaviour. For those fleeing violence this type of
accommodation can place them at increased risk.
The UK Government and devolved administrations ought to assess the extent to
which shelters are available to victims of VAWG, how they are funded and the
improvements needed to ensure compliance with Article 23.
Access to legal advice and representation for victims of VAWG is more difficult
following changes introduced by the Legal Aid, Sentencing and Punishment of
Offenders Act 2012, which may undermine compliance with Article 20. In family
law cases such as divorce, legal aid is now only available to people who can
demonstrate they have been victims of domestic violence. Sometimes the only
available evidence would be a medical report and, if the woman cannot afford to
pay for this, legal aid would be refused. A survey in the first three months of the
new regime indicated that half of women affected by violence did not have the
necessary evidence to support a legal aid application.24
21
The Leveson Inquiry Report on the Culture, Practices and Ethics of the Press was published in
November 2012 - http://www.levesoninquiry.org.uk/about/the-report/
22
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/181088/vawg-actionplan-2013.pdf p.26
23
Scottish Women’s Aid represents 38 women’s aid groups working across Scotland provide
accommodation and support services to women and to women with children http://www.scottish.parliament.uk/S4_EqualOpportunitiesCommittee/Inquiries/Scottish_Womens_Aid_
submission.pdf - page 3.
24
See http://www.rightsofwomen.org.uk/
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Further reforms to civil legal aid, announced by the Government in 2013,25 would
include the introduction of a residence test. Women and girls who are
undocumented may have particular difficulty satisfying the residence test.
Although exceptions would apply to certain cases involving domestic violence,
forced marriage and the protection of children, concerns have been raised that
the exceptions have been drawn too narrowly.26
b. Greater prioritisation and investment by the NHS in tackling VAWG (Article
20) – the health sector has not yet invested the resources required to effectively
tackle VAWG, as set out by the Taskforce on the Health Aspects of Violence
Against Women and Children.27 Implementing the Taskforce’s recommendations
through greater prioritisation by the National Health Service of VAWG as a major
public health issue could transform the provision of care and support for victims,
for example through improved identification of victims, provision of support and
appropriate referrals, and commissioning specialist services.
c. Addressing the negative impacts of recent changes in funding and
commissioning on equal access to specialist support services for victims
of VAWG across Britain (Article 22) – The UK Government’s VAWG Action
Plan suggests it is taking the necessary steps to meet the requirements of Article
22 in England and Wales.28 In addition, the Welsh VAW strategy pledges
£4.4million per annum, and the Scottish Government has committed to fund all
VAW programmes at the same level, in nominal terms, from 2012 to 2015.
However, the last three years has seen considerable change in funding and
commissioning women-only services in England, for example the increased
emphasis on local decision-making. Evidence submitted to the CEDAW
Committee in 201329 suggests there may be shortfalls so that specialist women’s
support services are not available to “all women victims of violence and their
children” as required by Article 22(2). Scottish Women’s Aid also reports that
84% of its 34 members are operating with either a reduced or standstill budget,
with 1 in 5 having to cut services as a result.30
To demonstrate compliance with Articles 20-25, the UK Government and
devolved administrations should analyse the impact on services of the current
funding arrangements. If it is found that the current approach to funding does not
meet these requirements, the obligation may need to be enshrined in domestic
legislation.
25
Transforming legal aid; delivering a more credible and efficient system, Ministry of Justice, April
2013
26
Human Rights Joint Committee - Seventh Report: The implications for access to justice of the
Government's proposals to reform legal aid (11 December 2013)
27
The report of the Taskforce on the Health Aspects of Violence Against Women and Children was
published in March 2010 - http://www.health.org.uk/media_manager/public/75/externalpublications/Responding-to-violence-against-women-and-children%E2%80%93the-role-of-theNHS.pdf
28
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/181088/vawg-actionplan-2013.pdf p.20-27
29
42 women’s and human rights organisations from across the UK, many of them involved in the
delivery of the front-line support services required by Articles 20-25 submitted a shadow report to the
CEDAW Committee in July 2013 - http://thewomensresourcecentre.org.uk/our-work/cedaw/cedawshadow-report/ Appendix 5 focuses on the provision of support services to victims of VAWG.
30
http://www.scottish.parliament.uk/S4_EqualOpportunitiesCommittee/Inquiries/Scottish_Womens_Aid
_submission.pdf - p3
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d. An amendment to the Immigration Rules to reflect the relevance of nondomestic VAWG to claims for residence following the breakdown of a
relationship (Article 59) – Under Chapter 8 Appendix FM of the Immigration
Rules,31 individuals who entered the UK as a partner and whose relationship has
since broken down as a result of domestic violence may be granted indefinite
leave to remain. However, this does not apply more generally to VAWG, so that a
woman whose relationship broke down subsequent to her suffering non-domestic
violence is not covered by the Rules. A narrow amendment to the Rules could
ensure those victims of non-domestic violence in the “particularly difficult
circumstances” envisaged by Article 59(1) are granted leave to remain. Where a
victim of VAWG is not granted leave to remain, the CEDAW Committee
recommended they should be provided with access to justice and healthcare until
their return to their countries of origin.32
e. Shortcomings in the gender sensitivity of the asylum system (Article 60) – a
number of deficiencies in the UK’s gender sensitive reception and support
procedures undermine compliance with Article 60(3) and should be remedied,
including:
 Women may be housed on the same corridors as men, and may not
always be able to lock their doors.
 The very low level of support for pregnant women seeking asylum.
 The lack of access to psychological care.
The CEDAW Committee has also recommended the UK Government “continue
to provide training to officers who are in charge of immigration and asylum
applications on gender-sensitive approaches in the treatment of victims of
violence.”33
6. Investigation and Prosecution
a. A criminal offence of intentionally seriously impairing a person’s
psychological integrity through coercion or threats (Article 33) – the
legislation, or its current interpretation in R v D,l34 creates a lacuna, which
undermines compliance with Article 33. In this case, the Court of Appeal
confirmed that psychological injury, not amounting to recognisable psychiatric
illness, falls outside the ambit of ‘bodily harm’ under Offences Against the
Person Act 1861. This lacuna could be addressed by inserting a definition into
the 1861 Act to confirm that harm can include “serious impairment of a
person’s psychological integrity” and a caveat in each of the relevant offences
(s.47, 20 and 18) that harm of that type will only be sufficient where it is
intentionally inflicted.
b. The criminalisation of forced marriage (Article 37) – the UK Government is
addressing this through the Anti-Social Behaviour, Crime and Policing Bill.
The Scottish Government is expected to lodge a motion with the Scottish
31
https://www.gov.uk/government/collections/chapter-8-appendix-fm-family-members-immigrationdirectorate-instructions
32
http://tbinternet.ohchr.org/_layouts/treatybodyexternal/Download.aspx?symbolno=CEDAW%2fC%2f
GBR%2fCO%2f7&Lang=en – para 57.
33
http://tbinternet.ohchr.org/_layouts/treatybodyexternal/Download.aspx?symbolno=CEDAW%2fC%2f
GBR%2fCO%2f7&Lang=en – para 59.
34
R v D [2006] EWCA Crim 1139 http://www.bailii.org/ew/cases/EWCA/Crim/2006/1139.html
9
Parliament, outlining the provisions in the Bill concerning devolved matters
and proposing that Westminster legislate on their behalf. Together, these
would also implement one of the CEDAW Committee’s 2013 Concluding
Observations.35
c. The extension of extra-territorial criminal jurisdiction (Article 44) - s72 of
the Sexual Offences Act 2003 for England and Wales provides a precedent
for the type of jurisdiction envisaged by Article 44(1). It creates active
personality jurisdiction for specified offences committed against a child – to
cover offences against children by British nationals engaged in ‘sex tourism’.
That jurisdiction could be extended to cover the range of offences within the
Istanbul Convention.
To discharge its obligation under Article 44(2) on passive personality
jurisdiction (which only requires that they endeavour to take the necessary
measures), the UK Government could consult on the issue, albeit it appears
unlikely that such a proposal would command support.
d. The extension of Multi Agency Public Protection Arrangements (MAPPA)
categories 1 and 2 to cover offences covered abroad (Article 51) – the
multi-agency public protection arrangements (MAPPA) in England and Wales
coordinate the management of dangerous individuals; and the multi agency
risk assessment conferences (MARACs) identifies individuals at high risk of
domestic abuse and coordinate responses, are apt to meet the requirements
of Article 51, subject to their proper application.
One small change would be to include offenders whose offences committed
were outside the UK in MAPPA categories 1 (registered sexual offenders) and
2 (murderers, or persons convicted of an offence specified in Sch 15 of the
Criminal Justice Act 2003 for England and Wales). This would mean those
offenders were subject to more rigorous assessment and management; and
would address the UK’s lack of recognition of offences committed abroad by
violent partners so that, currently, if a woman flees a violent partner and
travels to the UK and he follows her, UK Courts cannot apply restrictions on
him for offences he has committed abroad.
To improve the effectiveness of MARACs, the UK Government could review
their effectiveness to ensure lessons are being learned; and place them on
equal footing with the MAPPA concept by enshrining MARACs in domestic
legislation.
e. Consistent implementation of the law on consent (Article 36) - Despite
legislation and judicial interpretation consistent with Article 36, the
implementation of the law on consent is not always satisfactory as noted in
the Stern Review.36 The Article 36 obligation could be better met if specific
guidance was issued and training provided to Crown Prosecution Service
35
http://tbinternet.ohchr.org/_layouts/treatybodyexternal/Download.aspx?symbolno=CEDAW%2fC%2f
GBR%2fCO%2f7&Lang=en – para 35.
36
Baroness Vivien Stern CBE’s Independent Review into how Rape Complaints are Handled by
Public Authorities in England and Wales was published in March 2010 http://webarchive.nationalarchives.gov.uk/20110608160754/http:/www.equalities.gov.uk/PDF/Stern_R
eview_acc_FINAL.pdf - p.115
10
lawyers and advocates in England and Wales on the law of consent in sexual
offences committed in the context of domestic violence.
11