text:
Top Picks : News Capsule , Awards | Honours , 2012 Current Affairs , December 2012 Current Affairs
London's Olympic champions on 29 December 2012 had been generously rewarded for their exploits in a special New Year Honours list, with Bradley Wiggins and Ben Ainslie receiving knighthoods.
Bradley Wiggins with his historic Tour de France triumph is the first British cyclist to be awarded with the honors. He had won a fourth Olympic gold medal and first on the road. On the other hand Ben Ainslie became the most successful Olympic sailor of all time with his fourth successive gold.
Along with Bradley Wiggins and Ben Ainslie, inspiring British Cycling performance director Dave Brailsford is also knighted as he once again masterminded a stunning medal haul as well as leading Team Sky to a one-two in the Tour de France.
The fourth knighthood went to David Tanner, the performance director for British Rowing, who also overseen a record medal pull as Britain's rowers won four golds and nine medals in all.
Four Olympic stars are made CBEs, including the king and queen of British athletics, Mo Farah and Jessica Ennis, after they lit up the Olympic Stadium.
London was the a final performance or effort for cyclist Victoria Pendleton, who added a second Olympic gold and is made a CBE after playing a trailblazing role for women sprinters on the track.
Rower Katherine Grainger receives the same honour in the year she finally made it gold with Anna Watkins in the double sculls following three successive silvers.
Three of Britain's double gold medallists have been awarded OBEs - dressage star Charlotte Dujardin and cycling couple Jason Kenny and Laura Trott - along with tennis' Andy Murray, who was both a gold medallist and a grand slam winner in 2012.
Long jumper Greg Rutherford, another gold medal winner in the Olympic Stadium on that Super Saturday, has been given an MBE. Also honoured with MBEs are 51-year-old three-day eventer Mary King, who won team silver in London, and gymnast Louis Smith, now a three-time Olympic medalist.
About New Year Honour
The New Year Honours is a part of the British honours system, where New Year's Day, 1 January, is marked by naming new members of orders of chivalry and recipients of other official honours. A number of other Commonwealth Realms also mark this day in this way.
The awards are presented by or in the name of the reigning monarch British honours are published in supplements to the London Gazette.
Honours have been awarded at New Year since at least 1890, in which year a list of Queen Victoria's awards was published by the London Gazette on 2 January.
GAJENDER SINGH, 7 Months Ago
Yes, these g.k notes are beneficial for competition exam.
Sivasakthi T, 7 Months Ago
Dear Sir, The current affairs are really very useful to us which includes the quick digest and highlights for easy understanding of the readers. Excellent sir.
RASIGA S, 7 Months Ago
It is an useful thing that people have to be aware
shalom john, 1 Year Ago
i wish that you help me to find out defense service i want to serve my mother land and i completed my MBA+PGDM so please help me out .
Prakash yadav, 1 Year Ago
acyually i had dream to join indian army bt i have to write 2nd puc supplementary exam so what should i do now
vineet, 1 Year Ago
done b.tec in mechanical stream ....now wanna apply for indian navy which brach suits me best?
DEBASISH GHATAK, 1 Year Ago
Dear Sir Pls advise how to apply for my nephew who is 18+ and had just passed 12 from NIOS with English / accountancy as subject.
Rahul solanki, 1 Year Ago
Sir I m passed by arts subject so can I apply for navy because I wanna go in navy please inform me then I applying


text:
50%Off code
50% Off App Center
Save on Apps with this promo code at LeapFrog....E5Z Get Promo Code
These LeapFrog promo codes have expired but may still work.
Our team is confident that we have found the newest LeapFrog coupons. Feel free to check similar sites and share with us if we missed something.

subset: commoncrawl


text:
gallery of plants
tech blog
plant profiles
mailing lists
top stories
shorturl service
tom clothier's archive
Gallery of Plants
Tech Blog
Plant Profiles
Mailing Lists
Search ALL lists
Search help
Subscription info
Top Stories
sHORTurl service
Tom Clothier's Archive
Follow @hort_net
Top Stories
New Trillium species discovered
Disease could hit Britain's trees hard
Ten of the best snowdrop cultivars
Plant protein database helps identify plant gene functions
Dendroclimatologists record history through trees
Potato beetle could be thwarted through gene manipulation
Hawaii expands coffee farm quarantine
Study explains flower petal loss
story archive
ADMIN: Subject Tags
[iris] ADMIN: Subject Tags
John I Jones
Date: Wed, 22 Feb 2006 22:01:04 -0800
List-archive: <
> (Web Archive)
Seems like it is time for me to remind everyone about using subject tags.
Please use the standard iris-talk subject tags, as described in the welcome message, to preface the subject lines of the messages you send to the list. For the people who use filters to sort their mail the subject tags are critical. Additionally, because of the large membership of this list, the tags are for the benefit of those who have no interest in certain types of Irises.
Remember, the format is the tag in ALL CAPS followed by a colon (:), followed by your subject. (no space between the subject tag and the colon)
[Subject tag]:[your subject description]
The colon is a very important part of the tag. The standard tags are below. You might want to print this for reference. Following the list of subject tags is a previous post by Anner, which I greatly appreciate, that describes in more detail how to use the tags. (Thanks again Anner)
TAG Used For
---- --------
TB: tall bearded irises
MED: median and dwarf bearded irises
AR: arilbred and aril irises
SIB: Siberian irises
LA: Louisiana irises
JI: Japanese irises
SPU: spuria irises
PCN: Pacific coast native irises
BULB: bulb irises (Dutch, reticulatas, Junos)
SPEC: iris species (particularly those not covered in another category)
REB: reblooming irises
SA: space-age irises
HIST: historic irises and history of iris development
CULT: culture
HYB: hybridizing
REF: references (books and society publications)
SHOW: iris shows and related topics
IRC: IRC chat sessions (currently Friday nights)
AIS: American Iris Society business and issues
PHOTO: iris photography
COMP: iris-related computer topics (record keeping, photo digitizing, etc.)
CAT: iris catalogs and discussion of commercial nurseries
AD: iris-related advertisement (ads not related to irises are *not*
TRADE: Posts to the list offering trades or looking for a particular iris. Replies to these posts should be made off-list privately to the original sender.
OT-PLANTS: other garden plants (not irises)
OT-ART: iris-motif art and craftwork
OT-HUMOR: iris-related humor
OT-CHAT: personal messages and conversation (consider taking it off-list!)
OT-BIO: introduction from a new subscriber (please follow with your name)
ADMIN: Reserved for list owner
This long post is for New Members and any other persons who have been confused about HOW to use Subject Tags. Other people have already spoken to WHY to use Subject Tags. I just thought I might be able to help a little.
First, the Subject line of a post consists of a Tag and then your title. The Tag is an abbreviation that puts the post into a broad category. The title then introduces the content of the post. The goal of both is to get people to open up your post and read what it is you are trying to communicate. In the subject line at the top of my post the OT-CHAT is the Tag. The rest is the title.
When a post is written it should be assigned a Subject Tag. Almost every post will fit into one of the Tag Categories. Many will fit into several. Tags may be combined, but all you really need is one good one. Tags may not be invented. Everyone will not assign tags in exactly the same way. That is okay.
Let us meet the tags, then we will see how to use or link them as necessary.
First, All posts are either ON Topic, or OFF Topic. The Topic of the list is IRISES.
On Topic posts carry the following Subject Tags.
*KINDS OF IRISES* (These follow the divisions of the American Iris Society.)
Discussions of Tall Bearded irises get assigned a TB. Discussions of Siberian Irises may be assigned a SIB. Discussions of Species irises may be assigned a
SPEC, and so forth.
*SPECIAL KINDS OF IRISES* (Subgroups with passionate followers).
REB: Assigned to Reblooming irises, or rebloom reports or REB issues in general.
SA: Assigned to Space Age irises, or the issues surrounding them.
HIST: Assigned to Historic Irises, or the issues surrounding them.
*HORTICULTURAL TAGS* (Garden stuff)
CULT: Issues concerned with how to grow irises, how to care for them, how to fight pests, how to keep the beds tidy and so forth. This category covers a broad range of issues, and issues of broad appeal.
HYB: This is for issues relating to hybridizing, which includes genetics and practicalities.
*SOCIETY ISSUES* ( American Iris Society Issues)
AIS: Which is for posts dealing with AIS issues and AIS Business
SHOW: Which is for topics associated with Iris Shows, and show reports.
REF: For discussions of books, publications and other reference resources
CAT: For posts related to catalogs and commercial nurseries.
COMP: For computer related discussions: databases and the like.
PHOTO: For camera and photography issues and questions.
AD: A tag by which a list member can advertise Iris related goods or services.
TRADE: Posts to the list offering trades or looking for a particular iris. Replies to these posts should be made off-list privately to the original sender.
OT-BIO: The tag for a a new member introducing himself, and others welcoming her.
OT-HUMOR: The tag for the story or clean joke you cannot resist sharing.
OT-CHAT: personal messages and conversation (consider taking it off-list!)
OT-PLANTS: For questions or brief discussion of non-iris plants and their culture.
OT-ART: For arts and crafts issues, noncommercial, see AD above.
And there is ADMIN, which is restricted to use fo the List Owner.
Okay, so now let's practice.
Say you want to make a post asking where to find a list of the official AIS iris size categories like Tall Bearded and Median. Use AIS: REF. Moving fast? Use: REF.
You want to know whether to cut back your foliage in September? CULT will do it. You want to make sure the SIB folks don't assume your post is about bearded foliage when you are asking about Siberians? SIB: CULT:
You want to ask about the Historic Spuria MRS. TAIT and whether it is really true that Bertrand Farr of all people introduced it? A good tag here would be a combined one HIST: SPUR: That will catch the eye of both the people interested in historics and in spurias.
You want to ask a question about germinating the species Iris stolonifera? Here you would want the aril specialists to read your post, so AR: CULT would be good, but AR alone would probably do the trick since there are not that many posts in the category. You could also use AR: SPEC: CULT, but do you really need to?
You want to know whether your TB BATHESHEBA COMES can be expected to rebloom in Calgary? Use the tag TB: REB.
You want to hear more about your harebrained idea of hybridizing reticulatas that will rebloom in Texas? HYB: BULB: REB:
You want to know about a good book on irises of the 'forties? Try REF, or better yet REF: HIST. You will get an answer. HIST: REF: would also be okay. Most of the time it does not matter which of a pair of tags comes first.
You want to ask about what was decided about the AIS Library at a recent AIS Board Meeting? Use AIS. Just because books are involved doesn't mean you need REF, too.
You want to know whether the latest issue of the Medianite is being received? Well, there are not that many hot choices here, but MED would work. REF might but I'd use MED. It is a quick judgement call. Not an issue of fine points of distinction that must be anguished over.
You want advice about your Space Age Median HAGAR'S HELMET which is being devoured by borers? You could use SA, you could use MED, but the one you should use is CULT, because the real issue is a Cultural Problem: Borers. That the iris they are eating is a horned median is irrelevant unless that is the only one in the yard they are interested in and you think that may be significant and want to emphasize that.
You want to know about photographing your Juno species and getting the photos loaded up and linked to your personal collection database? Use PHOTO: COMP and the techies will come out of the woodwork. You probably don't need BULB or SPEC since the kind of iris involved is not the point.
You want to ask about corn poppies as companion plants? Use CULT since irises are the plants being companioned and thus it is an Iris Culture Question. You need to ask about something ghastly that has gone wrong with your pet hosta and it needs immediate attention and you don't know who else to ask. That is an OT-PLANTS.
As I said, often any of several different tags will work. If picking tags is hard for you, keep it real simple. Most of the tags are rarely used by anyone, but the following tags are used a lot since they cover a lot of territory or represent popular areas of discussion.
Use your OT tags. They very important since those are posts that many will want to pass over.
Every post does not have to carry every subject tag that could conceivably be seen as appropriate. If I write a post talking about a possibly faulty description of an historic 1935 JI in a catalog that was published in 1960 and later remarked upon ambiguously by an AIS Board Member in an AIS Bulletin, it is not necessary to string out "HIST: JI: CAT: AIS: REF: Bum Description of ISHGABBIBLE?" HIST: JI is all you need.
In short, the trick is to pick a tag that will catch the eye of those who will be interested in your post, or will have the answer you need. Pin down the main point of your question, and tag that, or one might say, FLAG IT for special attention.
I hope this helps a little.
Anner, in Richmond
John | "There be dragons here"
| Annotation used by ancient cartographers
| to indicate the edge of the known world.
To sign-off this list, send email to firstname.lastname@example.com with the
message text UNSUBSCRIBE IRIS
Prev by Date:
OSIS Meeting Notice and Invitation
Next by Date:
Re: AIS: Region 7 website
Previous by thread:
OSIS Meeting Notice and Invitation
Next by thread:
Re: AIS: Region 7 website
Other Mailing lists
Author Index
Date Index
Subject Index
Thread Index
1995-2017 Mallorn Computing, Inc.
All Rights Reserved.
Our Privacy Statement


text:
Click Here to
continue to Next Page
An owner operated company specializing in repair and installation of residential septic systems in Fairfield County, Ct., U.S.A.
We work in Easton, Ct. ; Westport, Ct. ; Weston, Ct. ; Fairfield, Ct. ; Southport, Ct. ; Wilton, Ct. ; Newtown, Ct. ; Stratford, Ct. ; Milford, Ct.;
Norwalk, Ct. ; Redding, Ct ; Darien, Ct. ; New Canaan, Ct. ; Shelton, Ct. ; Oxford, Ct. ; Greenfield Hill, Ct. ; Trumbull, Ct. ; Orange, Ct.
This site will provide useful, detailed information about septic systems in Connecticut.
It will help you make better choices about pending work or an ongoing problem.
"He" (his father, worried he might go to sea) "therefore sometimes took me to walk with him, and see joiners, bricklayers, etc. at their work, that he might observe my inclination, and endeavor to fix it on some trade or other on land. It has ever since been a pleasure to me to see good workmen handle their tools;..."
- Benjamin Franklin, from
The Autobiography
G. L. Scully Co.
This website was last checked or updated on April 4, 2016
The owner, Geoff Scully, is the webmaster and author of this site.
Site Map
Background Piano Music by Geoff Scully
Gravel Driveways
Sand * Stone * Fill * Topsoil
Small Deliveries Too!
(203) 268-3360
Expert Septic Repairs
Design & Installation
Residential Backhoe Work


text:
Sakura Hotel Ikebukuro, Tokyo
- Free WiFi
Main amenities
- 103 guestrooms
- Restaurant
- Breakfast available
- Airport shuttle
- 24-hour front desk
- Air conditioning
- Front desk safe
- Laundry service
- Multilingual staff
- Concierge services
- Free newspapers in the lobby
- Luggage storage
For families
- Laundry facilities
- Elevator/lift
- Bathtub or shower
- Dry cleaning/laundry service
What's around
- In Ikebukuro
- J-World Tokyo (0.9 mi / 1.5 km)
- St. Mary's Cathedral (2 mi / 3.2 km)
- Waseda University (2.1 mi / 3.5 km)
- Buddhist Temple (2.2 mi / 3.6 km)
- Shimo-Kitazawa (2.2 mi / 3.6 km)
Sakura Hotel Ikebukuro, Tokyofrom $18
- 4 Bed Group Room (Shared Bathroom)
- Single Room
- Twin Room (Bunk Bed)
- Men and Women (Shared Dormitory Room), Bunk Beds
- Family Room
- Japanese Room
- Superior Double Room with Sofabed
- Shared Dormitory (Women Only:Shared Bunk Beds)
- Superior Double Room
- Double Room
- Room, 1 Double Bed with Sofabed
More great choices
At a glance
Key facts
Hotel size
- This hotel has 103 rooms
- This hotel is arranged over 9 floors
- Check-in time starts at 3 PM
- Check-out time is 10 AM
Required at check in
- Credit card or cash deposit required
- Government-issued photo ID required
Travelling with others
- One child (10 years old and younger) stays free when occupying the parent or guardian's room, using existing bedding
- No cribs (infant beds)
- Pets not allowed
- Free WiFi in public areas
- Free WiFi in rooms
- Airport shuttle (available on request) *
- No parking
Nearby Three Star Tokyo hotels
In the hotel
- Buffet breakfast daily (surcharge)
- Restaurant
- 24-hour front desk
- Concierge services
- Dry cleaning/laundry service
- Laundry facilities
- Free newspapers in lobby
- Luggage storage
- Multilingual staff
- Number of buildings/towers - 2
- Elevator/lift
- Safe-deposit box at front desk
- Designated smoking areas
In the room
- Air conditioning
- Iron/ironing board (on request)
- Bathtub or shower
- Hair dryer (on request)
- Free WiFi
Top Tokyo hotels
Recently reviewed hotels in Tokyo
- Daiwa Roynet Hotel GinzaFrom
"It's very close to Tokyo train station and many shopping stores. The hotel is new and the room is very spacious."Jan 17, 2017
- New Otani Tokyo Executive House ZENFrom
"I loved this hotel a lot. The hotel staff was polite and knowledgeable. The bed was extremely comfortable, the linens were really high quality and the rooms are clean. I'll…"Jan 17, 2017
- Hotel Jal City Haneda TokyoFrom
"Offers a great shuttle system. Staff is friendly rooms are clean and roomy perfect if you need to repackages things before your flight. also a few convience stores located around…"Jan 17, 2017
- ARTIST HOTEL - BnA HOTEL KoenjiFrom
"BnA hotel is perfect for anyone who appreciates modern/street art. Our room was designed by a local artist, talk about literally living in art. The lobby serves as a drip coffee…"Jan 16, 2017
Nearby hotels
Also popular with travelers from the USA
Sakura Hotel Ikebukuro, Tokyo's small print
Also known as
- Hotel Ikebukuro
- Sakura Ikebukuro Tokyo
- Sakura Hotel Ikebukuro Tokyo, Japan
- Sakura Hotel Toshima
- Hotel Sakura Ikebukuro
- Ikebukuro Hotel
- Ikebukuro Sakura
- Sakura Hotel
- Sakura Hotel Ikebukuro
- Sakura Hotel Ikebukuro Tokyo
- Sakura Ikebukuro
- Sakura Ikebukuro Hotel
The Japanese Ministry of Health, Labour, and Welfare requires all international visitors to submit their passport number and nationality when registering at any lodging facility (inns, hotels, motels, etc. ). Additionally, lodging proprietors are required to photocopy passports for all registering guests and keep the photocopy on file.
Noise-free guestrooms cannot be guaranteed.
Some facilities may have restricted access. Guests can contact the property for details using the contact information on the booking confirmation.
Optional extras
Buffet breakfast is offered for an extra charge of JPY 350.00 per person (approximately)
Airport shuttle service is offered for an extra charge
We have included all charges provided to us by this hotel. However, charges can vary, for example, based on length of stay or the room you book.
Recent reviews
Good 3.9 /5 from 526 reviews
Very small room and bathroom
great service, everyone very friendly and helpful, would definitely recommend!
Good hotel overall. Located in 7~8 minutes walk from the station. Clean and comfort room. A bit old but well maintained. Native-speaking staff. Breakfast provided just at 3.5 USD. looked specialized for foreign travelers.
stayed in room 901. great view outside the public balcony. no view in room. sheets and quality of room is low compared with cheaper places ive stayed. the location was conveniently close to the train station.
Pros: Location is near JR line (Yamanote), 7/11 around the corner, cheap food nearby. Staff was tremendously helpful, very important when you don't speak japanese. The majority of japanese wouldn't understand English or able to help you out although they want to. Cons: Tiny room, wasn't a problem for us but for larger people maybe.
Is the description of this hotel not correct? Tell us


text:
- Headache
- Skin redness
What causes headache and skin redness? 7 possible conditions
See a list of possible causes in order from the most common to the least.
This condition is considered a medical emergency. Urgent care may be required.
Find information about chemical burns and how to prevent them. Learn about the causes, symptoms, and treatment of chemical burns.
Scarlet fever is an infection that can develop in people who have strep throat. Learn about the symptoms, treatment, complications, and prevention of scarlet fever.
Polycythemia vera (PV) is a bone marrow disorder in which the body produces an excessive amount of red blood cells. Red blood cells are responsible for carrying oxygen to all parts of the body. Blood is carrie...
Autonomic dysreflexia (AD) is a condition in which your involuntary nervous system overreacts to stimuli. It's also known as autonomic hyperreflexia.
This condition is considered a medical emergency. Urgent care may be required.
Learn how people often react to black widow spider bites. Read about how they can be treated and avoided.
MRSA is an infection caused by a type of staph bacteria that's resistant to many different antibiotics. Learn about its symptoms, causes, and treatment.
Please consult a healthcare professional if you have health concerns.
Click to add a symptom to your list
- Top Symptoms
Copyright © 2005 - 2017 Healthline Media. All rights reserved for Healthline. Healthline content is strictly informational and should not be considered medical advice. See a certified medical professional for diagnosis and treatment recommendations. Terms of Use | Privacy Policy


text:
One of the best magazine resources for exceptionally detailed information about living, working and traveling away from the US is the venerable Transitions Abroad.
Founded in 1977 by educational travel expert Dr. Clay Hubbs, it is the antithesis of glossy and slick, but it is all about useful and practical. European travel expert Rick Steves was a long-time columnist, but a lot of the contributors are just regular folks who don't write for a living, but have a lot of experience living in a variety of regions and nations. I've written two articles for the magazine, on family travel-related topics.
Sadly, the print publication folded earlier this year, but the good news is that the back issue archives since 1999 live on. Even better, the same helpful articles are now continuing in the new TAzine.
TAzine highlights include the "Resourceful Traveler" column written by our own Perceptive Travel editor Tim Leffel. In the May 'zine issue, Tim wrote about biking in Eastern Europe, with cycling details and links for the Czech Republic, Slovakia, Hungary, Poland and Romania. Another recent Leffel column is the comprehensive Budget Travel in South America.
The June TAzine includes a Lisa Chavis article about volunteering in a South African game preserve, and the Calendar covers European Music Festivals July-Sept 2008.
Upcoming TAzine issues:
- July [2008] focus: Central America and Mexico
- August focus: Asia and Australasia
- September focus: South America
- October focus: Africa and the Middle East
- Editorial schedule for rest of 2008
(Like this post? Subscribe to the Perceptive Travel blog by clicking this Feedburner link.)


text:
Technical Paper: Bill C-36, Protection of Communities and Exploited Persons Act
This paper provides an overview of the Supreme Court of Canada's findings in its December 20, 2013 Bedford decision and explains the basis for the Government's legislative response: Bill C-36, the Protection of Communities and Exploited Persons Act, which received Royal Assent on November 6, 2014 (S.C. 2014, c.25).
I: Bedford v. Attorney General of Canada[1]
In Bedford, the Supreme Court of Canada declared unconstitutional three Criminal Code offences addressing prostitution-related conduct on the basis that they violated section 7 of the Canadian Charter of Rights and Freedoms (the "Charter"). Section 7 protects the rights to life, liberty and security of the person and the right not to be deprived thereof except in accordance with the principles of fundamental justice. The offences at issue were:
- prohibition on keeping or being in a "bawdy house" for purposes of prostitution (section 210);
- prohibition on living on the avails of prostitution (paragraph 212(1)(j)); and,
- prohibition on communicating in public for purposes of prostitution (paragraph 213(1)(c)).
The Court suspended the declaration of invalidity for 12 months "considering all the interests at stake" and recognizing that
"how prostitution is regulated is a matter of great public concern, and few countries leave it entirely unregulated."[2]The declaration of invalidity would have taken effect on December 20, 2014, if Parliament had not enacted Bill C-36.
Application of section 7 analysis to the offences at issue in Bedford
The Court found that the three offences sufficiently contributed to increasing the risks of harm experienced by prostitutes such that the offences infringed their right to security of the person. The Court affirmed the application judge's holding that the evidence showed that the offences prevented people
"engaged in a risky — but legal — activity from taking steps to protect themselves from the risks".[3]
The Court went on to find that the legislative objectives of the bawdy house and communicating offences, which were primarily aimed at addressing public nuisance and community harms associated with prostitution, were far outweighed by the negative impacts of these offences on prostitutes' safety and security. The Court also concluded that the living on the avails offence went further than it needed to in order to address its legislative objective of preventing the exploitation of prostitutes and was, therefore, overbroad. The offences were therefore contrary to the principles of fundamental justice. More specifically, the Court found:
- The bawdy house offence (section 210) was grossly disproportionate in its serious impact on prostitutes' safety, since it prohibited "moving indoors" as a basic safety precaution. The heightened risks for prostitutes were not outweighed by the provision's objective, which the Court characterized as nuisance-related, namely
"to combat neighborhood disruption or disorder and to safeguard public health and safety".[4]
- The living on the avails offence (paragraph 212(1)(j)) was overbroad in scope relative to its objective, which is to
"target pimps and the parasitic, exploitative conduct in which they engage", because it punished everyone who "lives on the avails" of prostitution without distinguishing between those who exploit prostitutes and those who could increase their safety and security (e.g., bodyguards, managers, or drivers) or provide other legitimate business services to prostitutes (e.g., accountants and receptionists).[5]
- The communicating offence (paragraph 213(1)(c)) was grossly disproportionate in its impact on prostitutes' safety relative to its objective, which the Supreme Court said was to
"take prostitution off the streets and out of public view"in order to prevent the nuisance that street prostitution can cause. The provision's negative impact on the lives and safety of street prostitutes (e.g., by depriving them of an ability to screen customers before getting into their car) was a grossly disproportionate response to the nuisances caused by street prostitution.[6]
Throughout its analysis, the Court emphasized that the offences were directed at addressing the public nuisances and community health and safety issues caused by street prostitution and brothels, as well as the "parasitic exploitation" of prostitutes by pimps. The Court specifically found that the prohibitions were not directed at deterring prostitution more generally.[7]
Finally, the Court said that the Government had not presented evidence to justify the section 7 violations as reasonable limits demonstrably justified in a free and democratic society under section 1 of the Charter. In particular, the Court found that there was no evidence to show that the provisions were minimally impairing of the section 7-protected rights at stake, or that the positive impacts of the criminal prohibitions on broader societal interests outweighed their serious negative impacts on prostitutes' safety.
Other key points
The Court addressed only the challenged provisions, noting that the case was
"not about whether prostitution should be legal or not. [It was] about whether the laws Parliament has enacted on how prostitution may be carried out pass constitutional muster."[8] The Court also indicated that Parliament is not
"precluded from imposing limits on where and how prostitution may be conducted" and recognized that "the regulation of prostitution is a complex and delicate matter."[9]
The Court held that it did not need to decide the section 2(b) (freedom of expression) challenge to section 213 of the Criminal Code, previously upheld as constitutional by the Supreme Court of Canada in the 1990 Prostitution Reference,[10] given the findings in respect of section 7.
II: Response to Bedford: Bill C-36
The Supreme Court of Canada gave Parliament one year to respond to its findings in Bedford. Failing to respond legislatively would have resulted in decriminalization of most adult prostitution-related activities. Bill C-36 was introduced on June 4, 2014 in response to the Bedford decision. It received Royal Assent on November 6, 2014 and will come into force on December 6, 2014. Its overall objective is to reduce the demand for prostitution with a view to discouraging entry into it, deterring participation in it and ultimately abolishing it to the greatest extent possible.
Bill C-36 was informed by the evidence before the courts in Bedford, as well as the decision itself, the public consultations conducted by the Government in February and March of 2014, jurisprudence interpreting existing prostitution-related Criminal Code offences, the available research on prostitution in Canada, including relevant Canadian Parliamentary reports, as well as available international research on prostitution, including relevant government reports from other jurisdictions. A bibliography of the research that informed the development of Bill C-36 is attached at Annex A.
a) Objectives of the Legislation
Bill C-36 reflects a significant paradigm shift away from the treatment of prostitution as "nuisance", as found by the Supreme Court of Canada in Bedford, toward treatment of prostitution as a form of sexual exploitation that disproportionately and negatively impacts on women and girls. Bill C-36 signals this transformational shift both through its statement of purpose, as reflected in its preamble, and its placement of most prostitution offences in Part VIII of the Criminal Code, Offences Against the Person.[11]
Bill C-36's objectives are based on the following conclusions drawn from the research that informed its development:
- The majority of those who sell their own sexual services are women and girls.[12] Marginalized groups, such as Aboriginal women and girls, are disproportionately represented.[13]
- Entry into prostitution and remaining in it are both influenced by a variety of socio-economic factors, such as poverty, youth, lack of education, child sexual abuse and other forms of child abuse, and drug addiction.[14]
- Prostitution is an extremely dangerous activity that poses a risk of violence and psychological harm to those subjected to it,[15] regardless of the venue or legal framework in which it takes place,[16] both from purchasers of sexual services and from third parties.[17]
- Prostitution reinforces gender inequalities in society at large by normalizing the treatment of primarily women's bodies as commodities to be bought and sold. In this regard, prostitution harms everyone in society by sending the message that sexual acts can be bought by those with money and power. Prostitution allows men, who are primarily the purchasers of sexual services, paid access to female bodies, thereby demeaning and degrading the human dignity of all women and girls by entrenching a clearly gendered practice in Canadian society.[18]
- Prostitution also negatively impacts the communities in which it takes place through a number of factors, including: related criminality, such as human trafficking and drug-related crime; exposure of children to the sale of sex as a commodity and the risk of being drawn into a life of exploitation; harassment of residents; noise; impeding traffic; unsanitary acts, including leaving behind dangerous refuse such as used condoms or drug paraphernalia; and, unwelcome solicitation of children by purchasers.[19]
- The purchase of sexual services creates the demand for prostitution, which maintains and furthers pre-existing power imbalances, and ensures that vulnerable persons remain subjected to it.[20]
- Third parties promote and capitalize on this demand by facilitating the prostitution of others for their own gain. Such persons may initially pose as benevolent helpers, providers of assistance and protection to those who "work" for them.[21] But the development of economic interests in the prostitution of others creates an incentive for exploitative conduct in order to maximize profits. Commercial enterprises in which prostitution takes place also raise these concerns and create opportunities for human trafficking for sexual exploitation to flourish.[22]
Consequently, Bill C-36 recognizes that prostitution's victims are manifold; individuals who sell their own sexual services are prostitution's primary victims, but communities, in particular children who are exposed to prostitution, are also victims, as well as society itself. Bill C-36 also recognizes that those who create the demand for prostitution, i.e., purchasers of sexual services, and those who capitalize on that demand, i.e., third parties who economically benefit from the sale of those services, both cause and perpetuate prostitution's harms.
Accordingly, Bill C-36 seeks to denounce and prohibit the demand for prostitution and to continue to denounce and prohibit the exploitation of the prostitution of others by third parties, the development of economic interests in the exploitation of the prostitution of others and the institutionalization of prostitution through commercial enterprises, such as strip clubs, massage parlours and escort agencies in which prostitution takes place. It also seeks to encourage those who sell their own sexual services to report incidents of violence and leave prostitution.
Bill C-36 maintains that the best way to avoid prostitution's harms is to bring an end to its practice.
b) Offences: Purchasers and Third Parties
Purchasing Offence
Bill C-36 criminalizes, for the first time in Canadian criminal law, the purchase of sexual services. This new offence makes prostitution itself an illegal practice; every time prostitution takes place, regardless of venue, an offence is committed. In criminalizing those who create the demand for prostitution, Bill C-36 furthers its overall objective to reduce that demand, with a view to ultimately abolishing prostitution to the greatest extent possible.
Bill C-36's new purchasing offence prohibits obtaining sexual services for consideration, or communicating in any place for that purpose (section 286.1). This offence imposes maximum penalties of 5 years imprisonment where prosecuted by indictment and 18 months where prosecuted by summary conviction and escalating mandatory minimum fines. Purchasing sexual services from a person under the age of 18 is an even more serious offence. Although already prohibited in existing criminal law,[23] Bill C-36 moves this offence to Part VIII of the Criminal Code, along with most other prostitution offences, and increases the maximum penalty from 5 to 10 years imprisonment and the applicable mandatory minimum penalty for a subsequent offence from 6 months to one year.
The purchasing offence is carefully tailored to its objective of reducing the demand for sexual services. It is based on the existing offence that prohibits obtaining sexual services for consideration from persons under the age of 18 years and, accordingly, jurisprudence interpreting that offence assists in defining the scope of the new offence. Jurisprudence that interprets the meaning of "prostitution" is also instructive, given that "prostitution" is defined as the exchange of sexual services for payment.[24]
To determine whether a particular act constitutes a "sexual service for consideration" or "prostitution", the court will consider whether the service is sexual in nature and whether the purpose of providing the service is to sexually gratify the person who receives it. Specifically, a contract or agreement, whether express or implied, for a specific sexual service in return for some form of consideration is required.[25] In particular, the consideration must be contingent on the provision of a particular sexual service and the contract or agreement must be entered into before the sexual service is provided.[26] Sexual activity involving no expectation of getting paid for the services provided does not meet the test.[27] Sexual activity in the context of ongoing relationships also fails to meet the test, unless the evidence shows that the alleged consideration was contingent on the provision of a particular sexual service.[28] In one case, gifts given to the complainant were not viewed as consideration for sexual favours rendered, but rather as gifts given "dans le cadre plus large de la relation affective entre l'accusé et le plaignant".[29] Another case held that the phrase "sexual services for consideration" is not intended to apply to consensual actions between those having an affinity towards one another.[30]
The following activities have been found to constitute a sexual service or an act of prostitution, if provided in return for some form of consideration: lap-dancing, which involves sitting in the client's lap and simulating sexual intercourse;[31] masturbation of a client in the context of a massage parlour, whether or not the client climaxes;[32] and, sado-masochistic activities, provided that the acts can be considered to be sexually stimulating/gratifying.[33] However, jurisprudence is clear that neither acts related to the production of pornography,[34] nor stripping[35] meet the test. In most cases, physical contact, or sexual interaction, between the person providing the service and the person receiving it is required; however, acts for which consideration is provided that take place in a private room in a club and that are sexual in nature, but do not involve physical contact between the "client" and "performer", such as self-masturbation, have been found to constitute prostitution.[36]
In short, whether a particular service meets the test outlined above is a factual determination to be made by a court. Applicable jurisprudence provides flexibility in addressing new ways of effecting prostitution, while also limiting the scope of such offences to acts related to prostitution, consistent with its objective of reducing demand for sexual services.
Advertising Offence
To complement the purchasing offence, Bill C-36 criminalizes, also for the first time in Canadian criminal law, advertising the sale of sexual services. This new offence targets the promotion of prostitution through advertisements, which contributes to the demand for prostitution. This approach is consistent with the legislation's overall objective of reducing the demand for prostitution with a view to discouraging entry into it, deterring participation in it and ultimately abolishing it to the greatest extent possible.
Bill C-36's new advertising offence criminalizes knowingly advertising an offer to provide sexual services for consideration (section 286.4). This offence imposes maximum penalties of 5 years imprisonment where prosecuted by indictment and 18 months where prosecuted by summary conviction.
The advertising offence targets persons who place advertisements in print media or post advertisements on websites. Publishers or website administrators could be held criminally liable as parties if they know of the existence of the advertisement and that the advertisement is in fact for the sale of sexual services. Bill C-36 also allows the court to order the seizure of materials containing advertisements for the sale of sexual services, as well as their removal from the Internet, regardless of who posted them, which is also consistent with Bill C-36's objective of reducing demand for prostitution.
Material Benefit Offence
Bill C-36 creates a new material benefit offence that modernizes the living on the avails of prostitution offence, which was found unconstitutional inBedford. Consistent with Bill C-36's objective of continuing to denounce and prohibit the development of economic interests in the exploitation of the prostitution of others, as well as the institutionalization and commercialization of prostitution, Bill C-36 criminalizes receiving a material benefit from the prostitution of others in exploitative circumstances, including from participation in business activities involving prostitution from which third parties profit.
Specifically, the new material benefit offence criminalizes receiving a financial or other material benefit obtained by or derived from the commission of the purchasing offence (section 286.2). Where the victim is an adult, the maximum penalty is 10 years imprisonment; where the victim is a child, the maximum penalty is 14 years imprisonment and the mandatory minimum penalty is 2 years.
Bill C-36 does not prevent those who sell their own sexual services from entering into legitimate family and business relationships on the same basis as anyone else. In this regard, Bill C-36 narrows the scope of the material benefit offence through legislated exceptions, which clarify that the offence does not apply if the benefit is received:
- in the context of a legitimate living arrangement, for example by a spouse, child or roommate of the person who provides the benefit;
- as a result of a legal or moral obligation, for example by a dependent parent of the person who provides the benefit or where a gift is purchased with the earnings of prostitution;
- in consideration for goods or services offered on the same terms and conditions to the general public, such as by an accountant, landlord, pharmacist or security company; and,
- in consideration for a good or service that is offered informally, for example by a person who provides protective or administrative services, provided that the benefit received is proportionate to the value of the good or service provided and the person who provided the service did not encourage, counsel or incite the provision of sexual services.
None of these exceptions is applicable, however, if the person who received the material benefit from the prostitution of others:
- used or threatened to use violence, intimidation or coercion toward the person who provided the benefit;
- abused a position of trust, power or authority toward the person who provided the benefit;
- provided intoxicating substances to the person who provided the benefit to aid or abet that person's prostitution;
- engaged in conduct that would constitute procuring under the new procuring offence; or,
- received the benefit in the context of a commercial enterprise that offers sexual services for sale, such as a strip club, massage parlour or escort agency in which prostitution takes place.
These exceptions reflect jurisprudence that carves out exceptions to the living on the avails of prostitution offence. The "legitimate living arrangement" and "legal and moral obligation" exceptions find their origin in the Ontario Court of Appeal's 1991 Grilo decision,[37] which was cited as an authority on these issues by the Supreme Court of Canada in Bedford. The exception related to goods and services offered to the general public originates in a line of cases starting with the 1962 House of Lords decision in Shaw.[38] The fourth exception for services or goods provided for proportionate value responds to the Supreme Court of Canada's Bedford decision by exempting non-exploitative relationships.[39] Also, Bill C-36 provides an extra layer of protection in cases involving persons who initially pose as a benevolent helper and thereby appear to be entitled to one of the exceptions; it removes the availability of any of the exceptions if any exploitative circumstances materialize.
Although "commercial enterprise" is not defined, the phrase has been interpreted in sentencing cases under the Controlled Drugs and Substances Act.[40] Courts apply a contextual analysis to determine whether a particular enterprise is commercial in nature[41] which provides flexibility to the courts to find different types of enterprises, including informal ones, to be "commercial". In the context of Bill C-36, a "commercial enterprise" necessarily involves third party profiteering. Courts would likely take into account considerations such as the number of persons involved, the duration of the activities and the level of organization surrounding the activities. The only type of enterprise that this phrase cannot capture is one involving individuals who sell their own sexual services, whether independently or cooperatively, from a particular location or from different locations. Bill C-36 does not allow for prosecution in these circumstances for reasons outlined in the section below. Otherwise, Bill C-36 provides flexibility to the courts to find different types of enterprises, including informal ones, to be "commercial" in nature.
Bill C-36 also reformulates the presumption that applied to the living on the avails offence (subsection 212(3)), which allowed a prosecutor to prove an element of the offence by introducing evidence that the accused lived with or was habitually in the company of a prostitute. Similarly, Bill C-36's proposed subsection 286.2(3) allows a prosecutor to prove that an accused received a financial or material benefit from the sexual services of another by introducing evidence that the accused lived with or was habitually in the company of a person who offers or provides sexual services for consideration. The application of this presumption takes into account the scope of the material benefit offence as narrowed by the exceptions
In its 1992 Downey decision, the Supreme Court of Canada found that the subsection 212(3) presumption infringed the presumption of innocence as protected by section 11(d) of the Charter, but was justified as a reasonable limit under section 1. Specifically, the Court found that those who sell their own sexual services are often reluctant to testify against their "pimps", who "maintain control by the emotional dependence of prostitutes upon them or by physical violence" and that this problem is not unique to Canada, thereby justifying the enactment of a rebuttable evidentiary presumption.[42]
Procuring Offence
Bill C-36 modernizes the procuring offences in subsection 212(1), which used antiquated language and created significant overlap between offences by criminalizing similar conduct effected in different ways. Consistent with Bill C-36's objective of continuing to denounce and prohibit the procurement of persons for the purpose of prostitution, Bill C-36 prohibits comprehensively all conduct related to procuring others for the purpose of prostitution.Specifically, the procuring offence criminalizes procuring a person to offer or provide sexual services for consideration or recruiting, holding, concealing or harbouring a person who offers or provides sexual services for consideration, or exercising control, direction or influence over the movements of that person, for the purpose of facilitating the purchasing offence (section 286.3). Where the victim is an adult, the maximum penalty is 14 years imprisonment; where the victim is a child, the maximum penalty is 14 years imprisonment and the mandatory minimum penalty is 5 years.
Bill C-36's procuring offence can be proven in one of two ways. First, the offence can be proven if the accused "procured" another person for the purposes of prostitution. The term "procure" has been interpreted by the Supreme Court of Canada as meaning
"to cause, induce or have persuasive effect,"[43] which necessarily entails active involvement in the prostitution of another on the part of the accused. Second, the offence can be proven if the accused recruited, held, concealed or harboured a person for the purposes of prostitution or exercised control, direction or influence over the movements of a person for that purpose. This approach builds on existing jurisprudence interpreting one of the existing procuring offences[44] and the human trafficking offence,[45] both of which use some of the same language as found in new section 286.3.
The difference between the material benefit and the procuring offences hinges on the level of involvement in the prostitution of other persons. As with the procuring offences replaced by Bill C-36, the new procuring offence requires active involvement in the provision of another person's sexual services; whereas, passive involvement is sufficient to make out the material benefit offence. For example, a "classic pimp" is likely to be caught by both the procuring offence and the material benefit offence, because pimps generally induce or cause others to offer or provide their sexual services and they economically benefit from that activity. In contrast, a person who derives a benefit from the prostitution of others, without actively inciting the provision of sexual services, such as a "bouncer," who works at a strip club and knows that prostitution takes place there, is only caught by the material benefit offence.[46] This difference justifies the imposition of higher penalties for procuring.
c) Immunities: Sellers
Bill C-36 criminalizes the purchase but not the sale of sexual services. However, Bill C-36 in no way condones the sale of sexual services; rather, it treats those who sell their own sexual services as victims who need support and assistance, rather than blame and punishment. Research shows that individuals frequently engage in prostitution as a result of seriously constrained choices and/or because they have been coerced by unscrupulous individuals to do so.[47] This asymmetrical approach is also intended to encourage those who sell their own sexual services to report incidents of violence and exploitation committed against them, rather than seeking to avoid detection by law enforcement.
Accordingly, Bill C-36 expressly immunizes from prosecution individuals who receive a material benefit from their own sexual services or who advertise those services. It also immunizes those who sell their own sexual services for any part they may play in the purchasing, material benefit, procuring or advertising offences in relation to the sale of their own sexual services. Such prosecutions would otherwise normally be available by operation of general provisions of the criminal law that impose criminal liability on persons for various forms of participation in offences committed by other persons (i.e., liability for aiding, abetting or counseling another to commit an offence, conspiring with another person to commit an offence or being an accessory after the fact to an offence). These immunities mean that individuals cannot be prosecuted for selling their own sexual services, whether independently or cooperatively, from fixed indoor or other locations, as long as the only benefit received is derived from the sale of their own sexual services.
d) Offences: Community Harms
Bill C-36 protects communities, and especially children, from prostitution's harms by imposing higher mandatory minimum fines on those who purchase sexual services or communicate for that purpose in specified locations, i.e., parks, schools, religious institutions and places where children could reasonably be expected to be present. In this way, Bill C-36 is intended to send a particularly strong message to purchasers about the harms their conduct causes to vulnerable communities in its effort to reduce the demand for prostitution.
Bill C-36 also achieves its goal of protecting communities by criminalizing communicating for the purposes of selling sexual services in specific locations that are designed for use by children. As introduced, Bill C-36 proposed a summary offence that would have criminalized communicating for the purposes of selling sexual services in public places where children can reasonably be expected to be present. The scope of this offence was narrowed by the Standing Committee on Justice and Human Rights to prohibit communicating for the purposes of selling sexual services in public places that are or are next to school grounds, playgrounds or daycare centres (section 213(1.1), as enacted). This prohibition applies at all times and remains a summary conviction offence with a maximum penalty of 6 months imprisonment.
The main objective of the offence, as enacted, remains the same – to protect children from exposure to prostitution, which is viewed as a harm in and of itself, because such exposure risks normalizing a gendered and exploitative practice in the eyes of impressionable youth and could result in vulnerable children being drawn into a life of exploitation. The offence also protects children from additional harms associated with prostitution, including from being exposed to drug-related activities or to used condoms and dangerous paraphernalia. In not criminalizing public communications for the purposes of selling sexual services, except in these narrow circumstances, Bill C-36 recognizes the different interests at play, which include the need to protect from violence those who sell their own sexual services, as well as the need to protect vulnerable children from prostitution's harms.
Bill C-36 also retains, but modernizes, existing paragraphs 213(1)(a) and (b), which were not at issue in the Bedford case. These offences criminalize stopping or attempting to stop motor vehicles or impeding the free flow of pedestrian or vehicular traffic in public places or places open to public view for the purpose of either purchasing or selling sexual services. These are summary conviction offences with maximum penalties of 6 months imprisonment. Their objective is to protect residents of communities in which prostitution takes place from harassment by both those who purchase and those who sell sexual services.
e) Safety Issues
First and foremost, Bill C-36 seeks to ensure the safety of all by reducing the demand for prostitution, with a view to deterring it and ultimately abolishing it to the greatest extent possible. However, Bill C-36 recognizes that its transformational paradigm shift will take time to realize; changing social attitudes can be a long process. Bill C-36's approach, therefore, acknowledges that some will remain at risk of, or subjected to, exploitation through prostitution, while this transformation occurs.In response to this concern, Bill C-36 focuses law enforcement attention primarily on individuals who purchase sexual services, as well as on third parties who exploit individuals that sell sexual services. In addition, Bill C-36 does not prohibit individuals from taking certain measures to protect themselves when selling their own sexual services. In Bedford, the Supreme Court of Canada found that the impugned Criminal Code prostitution-related offences prevented sellers of sexual services from taking certain safety measures when engaging in a risky, but legal activity. These protective measures are: selling sexual services from fixed indoor locations, hiring persons who may serve to enhance safety and negotiating safer conditions for the sale of sexual services in public places. Bill C-36 seeks to balance these concerns with other broader safety and societal concerns posed by prostitution more generally: the need to protect those subjected to prostitution from violence and exploitation; the need to protect communities from prostitution's harmful effects, including exposure of children; and, the need to protect society itself from the normalization of a gendered and exploitative practice. In addressing this complex interplay of issues related to safety, the Supreme Court of Canada's concluding comments in its Bedford decision were instructive:
I have concluded that each of the challenged provisions, considered independently, suffers from constitutional infirmities that violate the Charter. That does not mean that Parliament is precluded from imposing limits on where and how prostitution may be conducted. Prohibitions on keeping a bawdy-house, living on the avails of prostitution and communication related to prostitution are intertwined. They impact on each other. Greater latitude in one measure — for example, permitting prostitutes to obtain the assistance of security personnel — might impact on the constitutionality of another measure — for example, forbidding the nuisances associated with keeping a bawdy-house. The regulation of prostitution is a complex and delicate matter. It will be for Parliament, should it choose to do so, to devise a new approach, reflecting different elements of the existing regime.[48]
Bill C-36 addresses the Supreme Court of Canada's safety concerns in the larger context of all the harms, risks and dangers posed by prostitution in the following way:
- Fixed Indoor Locations
The Supreme Court of Canada expressed concern that the existing prostitution offences prevent the selling of sexual services from fixed indoor locations, which the Court found to be a safer place to sell sex. Under Bill C-36, individuals cannot be prosecuted for selling their own sexual services, including from a fixed indoor location, whether independently or cooperatively.
- Bodyguards and Drivers
The Supreme Court of Canada's second major concern was that existing offences prevent those who sell sexual services from hiring bodyguards and others who may enhance their safety. Bill C-36 carefully balances this safety concern with the need to ensure that exploitative third parties are criminalized. It achieves this goal by: criminalizing receiving a financial or other material benefit that is obtained by or derived from the purchasing offence; limiting the scope of the offence through legislated exceptions, including exceptions that apply to individuals who offer protective services; and, ensuring that none of the exceptions apply in exploitative circumstances.
- Negotiating in Public Places
The Supreme Court of Canada's final concern was that individuals who sell their own sexual services should not be prevented from taking steps to negotiate safer conditions for the sale of sexual services in public places. One of the offences found unconstitutional by the Supreme Court of Canada criminalized all public communications for the purpose of either purchasing or selling sexual services. Bill C-36, on the other hand, creates, first, a new offence that criminalizes communicating in any place for the purpose of purchasing sexual services and, second, a separate offence that criminalizes communicating for the purpose of selling sexual services, but only in public places that are or are next to school grounds, playgrounds or day care centres. This approach strikes a careful balance between the interests of two vulnerable groups: those who are subjected to prostitution and children who may be exposed to it. Notably, Bill C-36 does not prohibit persons who sell their own sexual services from communicating for that purpose, other than in public places that are or are next to school grounds, playgrounds or day care centres.[49]
III: International Context
Canada is not alone in implementing a legislative approach to prostitution that views the practice as a form of sexual exploitation by targeting those who create the demand for it and those who capitalize on that demand. Sweden was the first country to implement such an approach in 1999, followed by Norway and Iceland in 2009, which is why Sweden's approach is referred to as the "Nordic Model". Furthermore, the Northern Ireland Assembly passed a bill that will criminalize paying for another person's sexual services in October 2014,[50] Ireland's Joint Committee on Justice, Defence and Equality recommended the Nordic Model in June 2013[51] and a March 2014 United Kingdom All-Party Parliamentary Report recommended implementation of a version of that approach.[52]
Moreover, the European Parliament endorsed the Nordic Model in February 2014[53] and, in April 2014, the Council of Europe recommended that member and observer states, which includes Canada, consider criminalizing the purchase of sexual services, as the most effective tool for preventing and combating human trafficking, and banning advertising sexual services and pimping.[54] The United Nations Committee on the Elimination of Discrimination against Women has also recommended or welcomed the criminalization of the purchase of sexual services and has stressed the importance of addressing the demand for prostitution.[55] In short, this approach is receiving growing international support as a sound policy approach, supported by an expanding body of evidence.
In 2008, the Swedish government appointed the Committee of Inquiry to Evaluate the Ban against the Purchase of Sexual Services, headed by Chancellor of Justice Anna Skarhed, a former Justice of the Supreme Court, to assess the ban against the purchase of sexual services from 1999 to 2008.[56] The Committee of Inquiry concluded that the Nordic Model was successful in deterring purchasers of sexual services, decreasing the number of prostituted persons and clients, and gaining favorable public support.[57] These conclusions were supported by other sources as well.[58] Furthermore, the Swedish Government has seen no concrete evidence that prostitution has merely been displaced and not reduced, e.g., moved from outdoor to other arenas, such as indoor locations, since implementation of the Nordic Model,[59] and evidence suggests that the criminalization of the purchase of sexual services has helped to combat prostitution and human trafficking for sexual purposes.[60]
In July 2014, the Norwegian government released a report assessing the effects of its 2009 ban on the purchase of sexual services,[61] which came to similar conclusions as the Swedish research, including that the ban had reduced the demand for sexual services, thus contributing to an overall decrease in the extent of prostitution and human trafficking in Norway. Furthermore, the evaluation did not find any evidence of increased violence against women in street-based prostitution following the coming into force of the law. The report concluded that the criminalization of the purchase of sexual services in Norway had met its intended goals.[62]
Since its implementation, some have raised concerns that the Nordic Model would drive prostitution underground, make human trafficking more difficult to detect and impact the safety and well-being of vulnerable women. Although some studies, mostly qualitative, have been conducted on these issues,[63] there is no concrete empirical evidence available to support the assertion that prostitution, which is already an underground activity given its nature and the prevalence of criminal elements even in decriminalized/legalized regimes, has been pushed further underground through the criminalization of purchasers.
On the other hand, research on the experience of countries such as Australia, Germany and the Netherlands shows that jurisdictions that have decriminalized or legalized prostitution tend to have larger sex industries than those that have not decriminalized or legalized prostitution.[64] Jurisdictions that have decriminalized or legalized prostitution have also experienced an expansion of their overall sex industries post-legalization/decriminalization,[65] especially outside the legal zones or regulated environments,[66] and individuals who sell their own sexual services continue to be vulnerable to violence and exploitation at the hands of third parties. Research indicates that coerced prostitution and human trafficking have flourished in both legal and illegal sectors,[67] and that social stigmatization of individuals who sell their own sexual services continues to prevail, while their overall "material conditions have not noticeably improved".[68] Finally, two recent empirical studies have shown that decriminalization and legalization are linked to higher rates of human trafficking for sexual exploitation.[69]
- [1] Bedford v Attorney General of Canada, [2013] SCJ No.72.
- [2] Ibid at paras 167-69.
- [3] Ibid at paras 60-92.
- [4] Ibid at paras 132-136.
- [5] Ibid at para 142.
- [6] Ibid at paras 158-59.
- [7] Ibid at paras 132-147.
- [8] Ibid at para 2.
- [9] Ibid at para 165.
- [10] Reference re ss. 193 and 195.1(1)(c) of the Criminal Code (Man.), [1990] 1 SCR 1123.
- [11] By contrast, existing prostitution offences are all placed in Part VII, Disorderly Houses, Gaming and Betting.
- [12] Quebec, Conseil du Statut de la femme du Québec, La prostitution: il est temps d'agir (2012) at 28, online: http://www.csn.qc.ca/c/document_library/get_file?uuid=9dfcb4ff-d60d-4c42-af9e-dfabadd202d5&groupId=2464358. See Canada, Subcommittee on Solicitation Laws, The Challenge of Change: A Study of Canada's Criminal Prostitution Laws, (Ottawa: Standing Committee on Justice and Human Rights, 2006) at 10, online: http://www.parl.gc.ca/HousePublications/Publication.aspx?DocId=2599932&Language=E&Mode=1&Parl=39&Ses=.
- [13] Conseil du Statut de la femme du Québec, supra note 12 at 47-8. See Canada, Subcommittee on Solicitation Laws, supra note 12 at 12-3. See Melissa Farley et al., "Prostitution and Trafficking in Nine Countries: An Update on Violence and Posttraumatic Stress Disorder" (2004) 2:3-4 Journal of Trauma Practice 33 at 37-8, online: http://www.prostitutionresearch.com/pdf/Prostitutionin9Countries.pdf
- [14] Canada, Subcommittee on Solicitation Laws, supra note 12 at 11-12. See Melissa Farley et al., supra note 13 at 48-9 and 65. See Conseil du Statut de la femme du Québec, supra note 12 at 29.
- [15] Conseil du Statut de la femme du Québec, supra note 12 at 52-55. See Melissa Farley et al., supra note 13. See Canada, Subcommittee on Solicitation Laws, The Challenge of Change, supra note 12 at 19-21. See Richard Poulin, "Prostitution et traite des êtres humains: controverses et enjeux" (2008) 45 Cahiers de recherche sociologique 135 at 4-5, online: http://sisyphe.org/IMG/pdf/Prost.traitePoulin.pdf . See Maddy Coy, Prostitution, Harm and Gender Inequality: Theory, Research and Policy (Burlington, VT: Ashgate, 2012). See Maddy Coy, Josephine Wakeling & Maria Garner, "Selling sex sells: Representations of prostitution and the sex industry in sexualised popular culture as symbolic violence" (2011) 34 Women's Studies International Forum 441 at 443.
- [16] Liz Kelly, Maddy Coy & Rebecca Davenport, "Shifting Sands: A Comparison of Prostitution Regimes Across Nine Countries" (Child & Women Abuse Studies Unit, London Metropolitan University, 2009) at 40-3, online: http://www.turnofftheredlight.ie/wp-content/uploads/2011/02/Shifting_Sands_UK-HOMe-Office.pdf .See Melissa Farley, "Bad for the Body, Bad for the Heart: Prostitution Harms Women Even if Legalized or Decriminalized" (2004) 10:10 Violence Against Women 1087, online: http://projectrespect.org.au/system/files/Prostitution +Harms+Women.pdf . See NZ, Prostitution Law Review Committee, Report of the Prostitution Law Review Committee on the Operation of the Prostitution Reform Act 2003, (New Zealand: Ministry of Justice, 2008), online: http://www.justice.govt.nz/policy/commercial-property-and-regulatory/prostitution/prostitution-law-review-committee/publications/plrc-report/documents/report.pdf .See NZ, Prostitution Law Reform in New Zealand, Parliamentary Library Research Paper (NZ: Parliamentary Library, 2012), online: http://www.parliament.nz/en-nz/parl-support/research-papers/00PLSocRP12051/prostitution-law-reform-in-new-zealand . See Melissa Farley, Prostitution and Trafficking in Nevada: Making the Connections (San Francisco: Prostitution Research and Education, 2007). See Jess N. Gibly, "Safe Sex for Sale: Is Legalizing Sex Work the Answer to Sex Trafficking in the Netherlands?" (2012) 4:1 International Journal of Undergraduate Research and Creative Activities at 1-11, online: http://commons.pacificu.edu/cgi/viewcontent.cgi?article=1004&context=ijurca . See Richard Poulin, "The legalization of prostitution and its impact on trafficking in women and children" (2005), online: http://sisyphe.org/article.php3?id_article=1596.
- [17] Conseil du Statut de la femme du Québec, supra note 12 at 34-42. See Canada, Subcommittee on Solicitation Laws, The Challenge of Change, supra note 12 at 17. See M. Dank et al. "Estimating the Size and Structure of the Underground Commercial Sex Economy in Eight Major US Cities" (2014) The Urban Institute, online: http://www.urban.org/UploadedPDF/413047-Underground-Commercial-Sex-Economy.pdf.
- [18] M. Coy, "Prostitution, Harm and Gender Inequality" supra note 15. See Conseil du Statut de la femme du Québec, supra note 12 at 31. See M. Coy et al., "Selling sex sells", supra note 15. See Janine Benedet, "For the Sake of Equality: Arguments for Adapting the Nordic Model of Prostitution Law to Canada" (2014), prepared for: Women's Coalition for the Abolition of Prostitution, online: http://www.rapereliefshelter.bc.ca/learn/resources/sake-equality-arguments-adapting-nordic-model-prostitution-law-canada. See Mary Sullivan & Sheila Jeffreys, "Legalising prostitution is not the answer: the example of Victoria, Australia" (Coalition Against Trafficking in Women: Australia) at 12, online: http://www.catwinternational.org/content/images/article/95/attachment.pdf.
- [19] Canada, Subcommittee on Solicitation Laws, The Challenge of Change, supra note 12 at 24-6, 31-4. See M. Coy et al., "Selling sex sells:" supra note 15 at 446. See M. Coy, Prostitution, Harm and Gender, supra note 15.
- [20] Janice G. Raymond et al., "A Comparative Study of Women Trafficked in the Migration Process: Patterns, Profiles and Health Consequences of Sexual Exploitation in Five Countries (Indonesia, the Philippines, Thailand, Venezuela, and the United States)" (N. Amherst, MA: Coalition Against Trafficking in Women, 2002), online: http://www.oas.org/atip/Migration/Comparative%20study%20of%20women%20trafficked%20in%20migration%20process.pdf. See Mary Honeyball, "Report on sexual exploitation and prostitution and its impact on gender equality," Committee on Women's Rights and Gender Equality, European Parliament, A7-0071/2014, online: http://www.europarl.europa.eu/sides/getDoc.do?type=REPORT%26reference=A7-2014-0071%26language=EN See UK Home Office. Tackling the Demand for Prostitution: A Review (United Kingdom, 2008), online: http://www.uknswp.org/wp-content/uploads/demandResponse.pdf. See Sigma Huda, "Special Rapporteur on the human rights aspects of the victims of trafficking in persons, especially women and children, Integration of the Human Rights of Women and a Gender Perspective", E/CN.4/2006/62, at paras 42-3, online: http://www.refworld.org/docid/48abd53dd.html . See Donna M. Hughes et al., "The Demand for Victims of Sex Trafficking", (2005) Women's Studies Program, University of Rhode Island.
- [21] Conseil du statut de la femme, supra note 12 at 34-9. See M. Dank et al., supra note 17 at 151. See Guylaine Paradis, Cousineau & Marie-Marthe Cousineau, "Prostitution juvénile: étude sur le profil des proxénètes et leur pratique à partir des perceptions qu'en ont des intervenantes-clés" (2005) Les Cahiers de recherches criminologiques 42. See Felicia Gabriele et al., "The incidence of human trafficking in Ontario" (2014) Alliance Against Modern Slavery, online: http://allianceagainstmodernslavery.org/events/release_of_research_report_on_human_%20trafficking_in_ontario
- [22] Conseil du statut de la femme, supra note 12 at 30-1. See Mary Sullivan & Sheila Jeffreys, "Legalising prostitution is not the answer: the example of Victoria, Australia" supra note 18 at 11. See Melissa Farley, "Prostitution & Trafficking in Nevada: Making the Connections" supra note 16 at 104-8. See Erika Schulze & Sandra Isabel Novo Canto, "Sexual Exploitation and prostitution and its impact on gender equality" Policy Department of the European Parliament – Citizen's Rights and Constitutional Affairs (2014) at 36, online: http://www.europarl.europa.eu/RegData/etudes/etudes/join/2014/493040/IPOL-FEMM_ET(2014)493040_EN.pdf See Jess N. Gibly, "Safe Sex for Sale: Is Legalizing Sex Work the Answer to Sex Trafficking in the Netherlands?" (2012) 4:1 International Journal of Undergraduate Research and Creative Activities 1-11, online: http://commons.pacificu.edu/cgi/viewcontent.cgi?article=1004&context=ijurca.
- [23] See subsection 212(4) of the Criminal Code.
- [24] Prostitution Reference, supra note 10 at para 45.
- [25] R v Phippard, [2005] NJ No.34 (Nfld. Prov. Ct.). See R v Lund, [2005] 288 AR 189 (Alta. Prov. Ct.); R v Watkins (2004), docket number: 200403T039, unreported (Nfld. SC).
- [26] Ibid. See R v Watkins, supra note 25. See also R v M.G.B., [2005] ABPC 215 (Alta. Prov. Ct.), in which the accused agreed to pay the complainant after the sexual act was completed; the court dismissed charges under subsection 212(4) without reasons, but convicted on child sexual offences.
- [27] R v Lee, [1998] NWTJ No.113 (NWTSC).
- [28] R v Phippard, supra note 25.
- [29] R v Jobin, [2007] QCCQ 1227 (CQ).
- [30] R v Leo, [1993] 147 AR 161 (Alta. Prov. Ct.), appeal against conviction dismissed by Alta. CA and SCC, without reasons.
- [31] R v Caringi, [2002] OJ No.2367 (Ont. C.J.), appeal dismissed [2005] OJ No.766 (Ont. CA). See R v Akouros, [2006] OTC 67 (Ont. SCJ).
- [32] R v Ni, [2002] 158 OAC 230, 53 WCB (2d) 485 (Ont. CA). See R v Brandes, [1997] OJ No.5443 (Ont. CJ (Prov. Div.)).
- [33] R v Bedford [2000] 143 CCC (3d) 311, 184 DLR (4th) 727 (Ont. CA), leave to appeal to S.C.C. refused 147 CCC (3d) vi, 193 DLR (4th) vii. See R v Wahl, [1999] JQ no.2540 (Cour municipale de Montreal).
- [34] R v Bauer, [1999] OJ No. 5294 (Ont. CJ). See R v Natarajan, [1995] 177 AR 190, 29 WCB. (2d) 379 (Alta. Prov. Ct.).
- [35] R v Saftu, [2002] OJ No.3046 (Ont. CJ). See Bauer, supra note 34.
- [36] R v St-Onge, [2001] 155 CCC (3d) 517, 44 CR (5th) 395; 50 WCB (2d) 485 (QCA.). See R v Tremblay, [1991] 41 QAC 241, 68 CCC (3d) 439, 14 WCB (2d) 490 (QCA).
- [37] R v Grilo, [1991] 2 O.R. (3d) 514 (Ont. C. A.), cited in Bedford, supra note 1 at para 141.
- [38] Shaw v Director of Public Prosecutions, [1962] AC 220 (H.L.), cited in Bedford, supra note 1 at para 141.
- [39] Bedford, supra note 1 at para 142.
- [40] Jurisprudence shows that courts will consider drug offences committed in the context of a "commercial enterprise" as an aggravating factor for the purpose of sentencing under the Controlled Drugs and Substances Act.
- [41] R v Gobran, [2013] 308 OAC 12 (OCA).
- [42] R v Downey, [1992] SCJ No. 48 at para 46.
- [43] R v Deutsch, [1986] SCJ No. 44 at para 32.
- [44] See subsection212(1)(h) of the Criminal Code, which prohibits, for the purposes of gain, exercising control, direction or influence over the movements of a person in such a manner as to show that he is aiding, abetting or compelling that person to engage in or carry on prostitution with any person or generally. See R v Perrault, [1997] RJQ 4 (QCA) interprets the meaning of "exercises control, direction or influence over the movements of...".
- [45] See section 279.01 of the Criminal Code, which prohibits recruiting, transporting, transferring, receiving, holding, concealing or harbouring a person or exercising control, direction or influence over the movements of a person, for the purpose of exploiting them or facilitating their exploitation. "Exploitation" is defined in section 279.04. These provisions were enacted in 2005. There is some jurisprudence interpreting the offence, for example: R c Urizar, [2013] JQ no. 132 (QCA) and R v Beckford and Stone, [2013] OJ No. 371 (Ont. SCJ), in which the constitutionality of section 279.011 (trafficking in children) was upheld. Section 279.011 is identical to section 279.01, with the exception that it imposes mandatory minimum penalties for trafficking children.
- [46] A person who receives a material benefit in the context of a commercial enterprise that offers sexual services for consideration would not be entitled to any of the legislated exceptions to the material benefit offence, including the exception that applies to persons who offer protective services, by virtue of paragraph 286.2(5)(e). This approach is consistent with Bill C-36's objective of prohibiting the commercialization and institutionalization of prostitution.
- [47] See research referenced at notes 14, 21 and 22.
- [48] Bedford, supra note 1 at para 165.
- [49] Where such activity is found to be harmful to children but occurs in private places, such as in the child's home, other Criminal Code offences, such as corrupting children (section 172), may apply. Provincial/territorial child welfare legislation also allows for state intervention where a child is in need of protection.
- [50] NIA Bill 26/11-15, Human Trafficking and Exploitation Bill, 2011-2015 sess, 2013, online: http://www.niassembly.gov.uk/Assembly-Business/Legislation/Current-Non-Executive-Bill-Proposals/Human-Trafficking-and-Exploitation-Further-Provisions-and-Support-for-Victims-Bill-/ See Northern Ireland, Committee for Justice, Report on the Human Trafficking and Exploitation (Further Provisions and Support for Victims) Bill (NIA 26/11-15), NIA 170/11-15, 10 April 2014, online: http://archive.niassembly.gov.uk/justice/report/human-trafficking/Report-on-Human-Trafficking-Bill.pdf
- [51] Houses of the Oireachtas, Joint Committee on Justice, Defence and Equality, Report on hearings and submissions on the Review of Legislation on Prostitution, June 2013, online: http://www.oireachtas.ie/parliament/media/committees/justice/1.Part-1-final.pdf
- [52] United Kingdom, All-Party Parliamentary Group on Prostitution and the Global Sex Trade, Shifting the Burden: Inquiry to assess the operation of the current legal settlement on prostitution in England and Wales, March 2014, online: http://prostitutionresearch.com/2014/04/29/shifting-the-burden-inquiry-to-assess-the-operation-of-the-current-legal-settlement-on-prostitution-in-england-and-wales/
- [53] European Parliament, Resolution on sexual exploitation and prostitution and its impact on gender equality, Adopted (26 February 2014), online: http://www.europarl.europa.eu/RegData/etudes/etudes/join/2014/493040/IPOL-FEMM_ET(2014)493040_EN.pdf. This resolution indicates that the European Parliament: endorsed the Nordic Model as one way of combating the trafficking of women and under-age females for sexual exploitation; recognized that prostitution and forced prostitution are intrinsically linked to gender inequality and have an impact on the status of women and men in society and the perception of their mutual relations and sexuality, that prostitution forced prostitution and sexual exploitation are highly gendered issues and violations of human dignity, that prostitution can have devastating and long-lasting psychological and physical consequences for the individual involved, especially children and adolescents, while perpetuating gendered stereotypes such as the idea that women's and under-age females' bodies are for sale to satisfy male demand for sex; and, stressed that prostitution markets fuel trafficking in women and children. See Mary Honeyball, Committee on Women's Rights and Gender Equality, European Parliament,Report on sexual exploitation and prostitution and its impact on gender equality, supra note 20.
- [54] Council of Europe, Resolution 1983, Prostitution, trafficking and modern slavery in Europe, Text Adopted (2014), online: http://assembly.coe.int/nw/xml/XRef/Xref-XML2HTML-en.asp?fileid=20716&lang=en.
- [55] Committee on the Elimination of All Forms of Discrimination against women, 8 February 2014, REC C/FIN /CO/7, online: http://formin.finland.fi/public/download.aspx?ID=127460&GUID=%7B50D3AE8D-B478-40D7-8B71-6EE474410022%7D. See Committee on the Elimination of All Forms of Discrimination against women, 9 March 2012, REC C/NOR/CO/8, online: http://www.fokuskvinner.no/PageFiles/3379/CEDAW-C-NOR-CO-8.pdf. Committee on the Elimination of All Forms of Discrimination against women, 30 July 2010, REC C/AUS/CO/7, online: http://www.refworld.org/publisher,CEDAW,CONCOBSERVATIONS,AUS,52dd07654,0.html.
- [56] National Public Investigations, Swedish Institute, "Prohibiting the purchase of sexual services: An evaluation 1999-2008", Report of the Commission on the evaluation of prohibiting the purchase of sexual service (SOU, 2010: 49), at 2, online: http://www.government.se/content/1/c6/15/14/88/0e51eb7f.pdf [English summary].
- [57] Ibid at 7-10.
- [58] Conseil du statut de la femme, supra note 12 at 90-100. See G. Ekberg, "Swedish Laws and Policies on Prostitution and Trafficking in Human Beings: An Overview. 2013", online: http://www.sccjr.ac.uk/wp-content/uploads/2011/12/Briefing-Law-and-policies-on-prostitution-and-THB-Sweden-Gunilla-S.-Ekberg-130704.pdf. See M. Waltman, "Prohibiting Sex Purchasing and Ending Trafficking: The Swedish Prostitution Law" (2010) 63:1 Political Research Quarterly 218-73, online: http://su.diva-portal.org/smash/get/diva2:460417/FULLTEXT01. See Working Group on the Legal Regulation of the Purchase of Sexual Services (Norway), "Purchasing Sexual Services in Sweden and the Netherlands: Legal Regulation and Experiences" [Abbreviated English Version] (Oslo, Norway: Ministry of Justice and the Police, 2004), online: http://www.regjeringen.no/upload/kilde/jd/rap/2004/0034/ddd/pdfv/232216-purchasing_sexual_services_in_sweden_and_the_nederlands.pdf. See Kajsa Wahlberg, "Trafficking in human beings for sexual and other purposes" (Situation report 13: Swedish National Police Board, 2012) at 21. See Joy Smith, "The Tipping Point: Tackling the Demand for Prostituted/Trafficked Women and Youth" 1st Report. (Canada: MP Kildonan – St. Paul, 2014), online: http://www.joysmith.ca/main.asp?fxoid=FXMenu,4&cat_ID=27&sub_ID=131&sub2_ID=70. See March 8 Initiative, "The Effects of the Swedish Ban on the Purchase of Sexual Services" (2012), online: http://www.regjeringen.no/upload/kilde/jd/rap/2004/0034/ddd/pdfv/232216-purchasing_sexual_services_ in_sweden_and_the_nederlands.pdf. See Evangelical Fellowship of Canada. Out of Business: Prostitution in Canada – Putting an End to Demand. Ottawa, (Canada: Centre for Faith and Public Life, 2013), online: http://files.efc-canada.net/si/ Prostitution/Out%20of%20Business.pdf.
- [59] National Public Investigations, supra note 56. See G. Ekberg, supra note 58. See M. Waltman, supra note 58.
- [60] Ibid at 9. See G. Ekberg, supra note 58. See M. Waltman, supra note 58. SeeHannah Carrigg, "Prostitution Regimes in the Netherlands and Sweden: Their Impact on the Trafficking of Women and Children in Illicit Sex Industries" (2008) 8 Monitor6, online: http://web.wm.edu/so/monitor/issues/14-1/1-carrigg.pdf. See Kaja Claude, "Targeting the sex buyer–the Swedish example: stopping Prostitution and trafficking where it all begins" (2014), prepared for: The Swedish Institute, online: https://eng.si.se/wp-content/uploads/sites/4/2013/02/Targeting-the-sex-buyer-English.pdf.
- [61] Rasmussen, Ingeborg, Strom, Steinar, Sverdrup og Vibeke Woien Hansen, Sidsel, ''Evaluering av forbudet mot kjop av seksuelle tjenester'' (2014) Vista Analyse, at 11-14, online : http://www.regjeringen.no/mobil/pages/38780386/Evaluering_sexkjoepsloven_2014.pdf.
- [62] Ibid.
- [63] Jay Levy & Pye Jakobsson, "Abolitionist Feminism as Patriarchal Control: Swedish Understandings of Prostitution and Trafficking" (2013) 37: 2 Dialectical Anthropology 333-340. See Daniela Danna, "Client-only Criminalization in the City of Stockholm: A Local Research on the Application of the "Swedish Model" of Prostitution Policy" (2012) 9:1 Sexuality Research and Social Policy 80-93. See Sandra Chu, Ka Hon & Rebecca Glass, "Sex Work Law Reform in Canada: Considering Problems with the Nordic Model" (2013) 51:1 Alberta Law Review 101-124, online: http://www.aidslaw.ca/publications/interfaces/downloadFile.php?ref=2193. See Susanne Dodillet & Petra Östergren, "The Swedish Sex Purchase Act: Claimed Success and Documented Effects" (2011) International Workshop: Decriminalizing Prostitution: Experiences and Challenges, online: http://www.chezstella.org/docs/etude-suede-2011.pdf. See A Krüsi et al., "Criminalisation of clients: reproducing vulnerabilities for violence and poor health among street-based sex workers in Canada—a qualitative study" (2014) 4 BMJ Open, online: http://bmjopen.bmj.com/content/4/6/e005191.full?keytype=ref&ijkey=dJU3wHl0LEkteB7.
- [64] Liz Kelly, Maddy Coy & Rebecca Davenport, "Shifting Sands: A Comparison of Prostitution Regimes Across Nine Countries" supra note 16 at 37.
- [65] Conseil du statut de la femme, supra note 12 at 88-90. See Janice G Raymond et al., "A Comparative Study of Women Trafficked in the Migration Process: Patterns, Profiles and Health Consequences of Sexual Exploitation in Five Countries (Indonesia, the Philippines, Thailand, Venezuela, and the United States)"supra note 20 at 150-51. See Janice G Raymond, "Ten Reasons for Not Legalizing Prostitution and a Legal Response to the Demand for Prostitution" (2004) 3:4 Journal of Trauma Practice 2 315 at 4-5.
- [66] Ibid at 89. See Janice G Raymond et al., "A Comparative Study of Women Trafficked in the Migration Process: Patterns, Profiles and Health Consequences of Sexual Exploitation in Five Countries (Indonesia, the Philippines, Thailand, Venezuela, and the United States)" supra note 20 at 150-51. See Working Group on the Legal Regulation of the Purchase of Sexual Services, "Purchasing Sexual Services in Sweden and the Netherlands" supra note 58.
- [67] Liz Kelly, Maddy Coy & Rebecca Davenport, "Shifting Sands: A Comparison of Prostitution Regimes Across Nine Countries" supra note 16 at 61-2. See Janice G Raymond et al., "A Comparative Study of Women Trafficked in the Migration Process: Patterns, Profiles and Health Consequences of Sexual Exploitation in Five Countries (Indonesia, the Philippines, Thailand, Venezuela, and the United States)" supra note 20 at 150-51. See Mary Honeyball, Committee on Women's Rights and Gender Equality, European Parliament, Report on sexual exploitation and prostitution and its impact on gender equality, supra note 20. See Working Group on the Legal Regulation of the Purchase of Sexual Services (Norway), supra note 58. See Janice G Raymond, "Ten Reasons for Not Legalizing Prostitution and a Legal Response to the Demand for Prostitution" supra note 63.
- [68] Liz Kelly, Maddy Coy & Rebecca Davenport, "Shifting Sands: A Comparison of Prostitution Regimes Across Nine Countries" supra note 16 at 47, 50-3. SeeJoyce Outshoorn, "Policy Change in Prostitution in the Netherlands: From Legalization to Strict Control" (2012) 9 Sex Research and Social Policy 233 at 242, online: http://www.nswp.org/sites/nswp.org/files/fulltext1%20(2).pdf. See New Zealand Government Prostitution Law Review Committee, Report of the Prostitution Law Review Committee on the Operation of the Prostitution Reform Act, supra note 16 at 58 & 69. See Melissa Farley, "Bad for the Body, Bad for the Heart: Prostitution Harms Women Even if Legalized or Decriminalized" (2004) supra note 16.
- [69] Niklas Jakobsson and Andreas Kotsadam, "Prostitution Laws and Trafficking for Sexual Exploitation" (2010) University of Gothenburg, Working Papers in Economics, no. 458 (Revised in 2013), online: https://gupea.ub.gu.se/bitstream/2077/22825/4/gupea_2077_22825_4.pdf. See Seo-Young Cho, Axel Dreher & Eric Neumayer, "Does Legalized Prostitution Increase Human Trafficking?" (2013) 41 World Development 67, online: http://www.lse.ac.uk/geographyAndEnvironment/whosWho/profiles/neumayer/pdf/Article-for-World-Development-_prostitution_-anonymous-REVISED.pdf.
- Date modified:


text:
|Bluebelle's Rescue
Always spay or neuter your pets. Visit Shelter Website
|Page 1
|Options: Reset
|Rescue Me ID: 16-05-07-00011Jackie (female)
Jackie was found on the streets after being hit by a car. She had a severe injury to her lip and the inside of her mouth, along with multiple areas of road rash and a muscle strain on her front leg. She has made a full recovery and is looking for her forever family! She is great with other dogs and people and loves to play! She is a master snuggler and loves to cuddle up on the couch for a good movie. Did we mention she is fully house and crate trained. If you are interested in adopting this girl, please email us at firstname.lastname@example.com.
Bluebelle's Rescue
Harris County Houston, TX MAP IT!
|Rescue Me ID: 16-05-06-00575Padme (female)
This gorgeous gal was found on the streets with her 2 babies. She had skin issues and was so skinny! She has since recovered and is doing fantastic in her foster home! She clearly loves playing with kids and is great with other dogs. She is fully vetted and heartworm negative (yay!). She is fully house trained and crate trained and is very well behaved. She loves to snuggle up on the couch and watch movies as well :) If you are interested in learning more about this pretty girl, please email us at email@example.com.
Bluebelle's Rescue
Harris County Houston, TX MAP IT!
|Rescue Me ID: 15-04-29-00299Cooper (male)
Cooper and his 3 siblings were pulled off the streets on a cold rainy night. They were found guarding their deceased mother in a ditch that was quickly filling with water. We quickly pulled them into safety and they have been recovering in a foster home now for a few weeks. Cooper is incredibly friendly with dogs, young children and cats. He loves to play and would make a great addition to any home. If you are interested in adopting him please email us at firstname.lastname@example.com or visit our website bluebellesrescue.org!
Bluebelle's Rescue
Harris County Houston, TX MAP IT!
|Rescue Me ID: 15-02-03-00675Dexter (male)
Dexter was found alone on the cruel streets of Houston. He is only 3 months old and is a total love bug! He loves playing with other dogs and does great with even young kids. He is up to date on shots and is currently still recovering from a mild case of demodex mange (also known as puppy mange). He is looking for a forever family! Email us at email@example.com if you are interested in learning more about him.
Bluebelle's Rescue
Harris County Houston, TX MAP IT!
|Check All That Apply Duplicate Post Spam/Possible Scam Inappropriate Photo Wrong Phone Number My Calls Not Returned
No Response to My Email "+JSVpcv+" Breeder Selling Animals (Posing as Rescue) Cancel
|Your problem report has been received. Thank you for helping keep this site accurate.
|How do you know this animal is no longer available?
This is my posting. I adopted this animal. Someone told me by phone or email. My calls or emails were never responded to. Other.
What is the current status of this animal?
Adopted (found a permanent home). Euthanized. Unknown. Other.
Cancel Cancel
|This animal has been reported as no longer available. Thank you for helping keep this site updated.
|Your information:
First Name: Last Name:
Your Email:
Send posting to my own email.
|Email this posting to up to three friends at once:
Friend 1 First Name: Email:
Friend 2 First Name: Email:
Friend 3 First Name: Email:
Send posting to yourself or fill in one, two or three friends above then hit... Cancel
|This posting has been sent successfully.


text:
Roddy White's unsolicited thoughts on Todd Haley
So it finally happened -- a confrontation between Steelers new offensive coordinator Todd Haley, well-known for his hot temper -- and a player.
A blowout with Big Ben? Sideline shouting with Emmanuel Sanders?
Uh, no.
It happened during Sunday night's game. While Haley was coaching. Over Twitter. By a player that Haley has never coached. And Haley had nothing to do with it.
Roddy White of the Atlanta Falcons had this to say about Haley:
Yahoo!'s Shutdown Corner blog posted a story about the tweet, and rightly questions why White found it necessary to say anything at all ...
Whether or not he has a point and Todd Haley really does think the show is about him, I don't know. I don't know how Roddy White would know, either. I'm sure he has friends around the league, and I'm sure everyone talks. Maybe it's just an observation White made from observing Haley from afar. Maybe their paths have crossed at some point.
In any case, it's so strange for White to interject himself here. He's not a Steeler. Haley isn't his coach. Whatever Todd Haley believes or doesn't believe about who's responsible for winning football games, I can't imagine why White would make it his concern.
If anything, one of the stories of this year's training camp has been that Haley hasn't been anything near the divisive figure he's been made out to be in the past. Receiver Antonio Brown gushed about Haley's personality and coaching style, discussing him at length a few weeks ago:"He's a great guy. Definitely not what people made him out to be." ...
"You can't go off of what you hear about a person until you really get to meet him, and, since I met this guy, he's been first class. ... [Haley] asks me what I'm seeing on the field and [makes suggestions] -- 'look at this route, you can do this better.' When you have men like that who are willing to ... be on the same page as players it makes it better for you, and you're more willing to want to play hard for them."


text:
Bing Kicks Off Summer With Better Video Search, World Cup Predictions
School's out. Microsoft spruces up Bing's online video search and turns its prediction engine on women's soccer.This summer, Microsoft is focusing some of its efforts on bulking up its Bing's video search capabilities. The company has given Bing's interface a makeover, including a new layout aimed at making videos easier and faster to find, the company announced Friday. Now, users are less likely to reach for their reading glasses or pinch-to-zoom while reviewing video search results. "We increased the size of the video thumbnail in our search results, giving an expanded view of the video and making it easier to find the video you want to watch," stated Microsoft's Video Search Team in a June 19 blog post. Search results now display supplemental information, including view count and upload date, before clicking on a video. In a mobile-friendly move, related searches now appear inline. "When you hit the bottom of the page, you'll get even more suggestions and the option to see more video search results. These updates improve touch-friendliness and scale better to tablets and other smaller screens," they added.
Microsoft is also making it easier to hunt down the music video pertaining to summer earworms.
Loading Comments...


text:
> Just one small correction. Damfino was introduced in 2005
That's correct. I use the registration year from the R&Is rather than
the introduction year. Some historics that are available don't give
the year of introduction. According to the R&I info, DAMFINO was
registered in '98, intro'd in '05.
10 Greatest Ever
Share and vote
on Bix.com!
Fashion News
What's the word on
fashion and style?
Staying in tonight?
Check Daily Picks &
see what to watch.


text:
Hotels in Campillo de Ranas
Hotel reservation
Campillo de Ranas
Hotel rooms in Campillo de Ranas
There are not so many hotel rooms in Campillo de Ranas, just 2, still everyone can find an offer to suit his choice. The most common offers in this city are hotels, they count 1 out of 2, and their prevalent location is central district. According to our practice, it is the most profitable to book a hotel in the west of Campillo de Ranas, as it is the location of the hotels with optimal cost and quality offers along with the cheap hotels. Taking into account the small size of the city, there is no need to dwell hotel reservation on the location: the road to the city center would take less then half an hour, so one can book a hotel in any district of Campillo de Ranas. The most populated with hotels district of Campillo de Ranas is the south, 50% of cheap hotel rooms are concentrated here. Campillo de Ranas is a truly multifaceted city, here everyone can find a hotel of his choice: a business person, a young couple or a family with little children. Take a look at our selection of the cheap hotel rooms in Campillo de Ranas to make a well-informed choice for your reservation!
Campillo de Ranas cheap hotels
Campillo de Ranas
All cheap hotels in Campillo de Ranas
Best hotels in Campillo de Ranas
Hotels in Campillo de Ranas are spread around the city within the distance of 3.2 kilometers, while 1 hotels are located directly in the city center. The most popular accommodations in Campillo de Ranas is
Casa Rural La Pizarra Negra
located in a 3.2 kilometers from the city center.
The best hotels are here and now. Try them!
All cities in Spain


text:
Search by
Registration for Children's Events
This event has already taken place. Click here for the latest events.Add to Calendar 03-01-2013 03-01-2013 15 Registration for Children's Events Register for several outstanding children's events - Snow Globe, Build It, Story Craft, Ice is Nice, Mitten Frame, and Winter Glitter Art and Embossed Jewelry Making. Registration begins January 3. http://www.nymetroparents.com/2015neweventinfo.cfm?id=123856 Franklin Square Public Library true DD/MM/YYYY
If you go: Please tell them you saw this event on
Upcoming Events at Franklin Square Public Library: