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High Court slams top family judge for not knowing what consent is

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Judge Tolson said woman was not raped because she had not ‘physically’ resisted unwanted sex

A High Court family judge has published a devastating attack on one of her colleagues, saying that experienced Family Court judge Robin Tolson has a “flawed” understanding of when sex becomes rape.

Ms Justice Russell slammed Tolson, the top judge at the Central Family Court in London, for suggesting in a written determination that refusing consent to sex involves physical resistance.

Tolson had ruled against a woman who said that she had been raped by her ex-partner, in part because “the mother did nothing physically to stop the father”.

Overturning the earlier judgment, Russell called for training to be rolled out to judges dealing with rape and sexual assault allegations in the Family Court.

The case was about making living arrangements for the young children of a unnamed couple. The mother alleged that she was the victim of domestic abuse by the father, including serious sexual assault.

A hearing took place before Tolson in August 2019. It seems to have been a shambles from the outset: Russell found that “the judge took the inexplicable step, contrary to the expressed view and request of the [mother], and contrary to the rules of procedure, of ordering that [she] give evidence from counsel’s row as ‘better’ than using the witness box and screens”.

Tolson also allowed the father, who had no lawyer, to receive prompts during cross-examination. Russell found that these “serious procedural irregularities” were enough in themselves to allow the appeal.

But she reserved her greatest ire for Tolson’s handling of the rape allegations. He wrote of one incident:

“During intercourse she told him to stop, but he did not, and carried on at least for “a couple of minutes”, which is a description given, I think, to the police. It is part of the mother’s case that she took no physical step to encourage the father to desist.”

The judge’s analysis of this was:

“My concern about this occasion centres on the idea that the mother did nothing physically to stop the father. In particular, given the position in which intercourse was occurring, because the mother was not in any sense pinned down on this occasion, but could easily, physically, have made life harder for the father. She did not do so.”

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A horrified Russell found that this take was “flawed”, saying: “This is a senior judge, a Designated Family Judge, a leadership judge in the Family Court, expressing a view that, in his judgment, it is not only permissible but also acceptable for penetration to continue after the complainant has said no (by asking the perpetrator to stop) but also that a complainant must and should physically resist penetration, in order to establish a lack of consent. This would place the responsibility for establishing consent or lack thereof firmly and solely with the complainant or potential victim.”

Russell pointed out that there is no legal rule that lack of consent must be shown by physical resistance. Her judgment says that “this approach is wrong, family judges should not approach the issue of consent in respect of serious sexual assault in a manner so wholly at odds with that taken in the criminal jurisdiction”.

“The logical conclusion of this judge’s approach”, Russell raged, “is that it is both lawful and acceptable for a man to have sex with his partner regardless of their enjoyment or willingness to participate”.

She added that calling Tolson’s views “out-dated”, as the mother had complained, was too kind to him.

The former 1GC Family Law silk, who was the first female judge to have “Ms” rather than “Mrs” in her formal title, called for mandatory consent training for family judges. The President of the Family Division, Sir Andrew McFarlane, has taken it up with the Judicial College.

Tolson, 61, was called to the bar in 1980 and took silk in 2001. Formerly in practise at St John’s Chambers in Bristol, he became a circuit judge in 2014 and the designated family judge at Holborn in 2015.

It’s a tough job: in 2017, an aggrieved divorce litigant was reportedly sentenced to 20 weeks in prison for assaulting Tolson outside court.

He previously hit the headlines for refusing 66-year-old Tini Owens a divorce in a case that eventually went up to the Supreme Court.

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59 Comments

Anonymous

“First female judge to have “Ms” rather than “Mrs” in her formal title.”

We’re really jumping through hoops for the first female narrative aren’t we?

(32)(13)

Ms Hale

‘The first female to perform a somersault in the courtroom… a true pioneer and promoter of female athletic superiority over men and equality for all womenkind’

(17)(2)

Anon

Her insistence on being called “Ms Justice” shows that she is ill-suited to hold judicial office. It demonstrates an obsessive adherence to a particular ideology; a lack of appreciation of the ridiculous; and (thus) a lack of judgment.

(84)(42)

Archduke of the Austrian Empire

I’m not familiar with judicial titles, is there usually a Mr or Ms before the Justice bit? Like would a male judge be called Mr Justice X, or just Justice X?

(0)(0)

Anon

No, moron.

(0)(6)

El Sinistro

The convention for High Court judges is “Mr Justice Bloggs” (if male) and “Mrs Justice Bloggs” if female; it becomes ‘Lord / Lady Justice’ in the Court of Appeal. We don’t use the ‘Justice’ by itself as a title in the way that other jurisdictions do.

I’m not sure what I think of the ‘Ms’ thing. In some ways it makes little difference, so I can’t see why it’d be an issue to use the conventional title (it’s an honorific at the end of the day and nobody makes any assumptions as regards marital status from it to my knowledge).

That said, I know several women at the Bar who practise under their maiden name and use their married name in a personal capacity, so whilst I might refer to them as “Miss Smith” in court, they might actually be “Mrs” something else. To that extent it’s somewhat understandable; if “Russell” is the learned judge’s professional name but her married name is something else, it’d be inaccurate, strictly speaking, to refer to her as “Mrs Justice [professional name]”.

What *is* ridiculous, if I may say so, is your preceding poster’s view that the decision to be referred to as ‘Ms’ is capable of supporting any inferences about the judge’s professional competence. Stop projecting your insecurities on someone who is – by definition – better at her job than most lawyers.

(12)(16)

Anon

Given the university she went to, Ms Justice Russell is by definition intellectually third rate. Which is why she chose family “law”. She would not have got within spitting distance of the commercial or chancery Bar. Her intellectual failings understandably affect her ability to discharge her judicial functions, too. This is demonstrated by her decision in this case, which show multiple forensic failings on her part.

JDP

Ok, you learn something every day.

(10)(2)

#thetideisturning

Mmm. What are the chances that if we actually read Tolson’s judgment, it would turn out that he didn’t say or in any way imply that “it is not only permissible but also acceptable for penetration to continue after the complainant has said no (by asking the perpetrator to stop) but also that a complainant must and should physically resist penetration, in order to establish a lack of consent”? 99%?

(37)(29)

Anon

I think you’re right. From the quoted passages of Tolson’s judgement it seems as though he doubted that she had ever said “no” at all. The father’s case was that the sex was consensual throughout and that she never said “no” at all.

Presumably if Tolson had ever made a finding that she had said no then this would have been referenced.

Further, a friend of the mother told the police “I asked her what had happened and she said that she had let the [Respondent] have sex with her as it was easier than saying no.” Again, this backs up the view that she never said no.

The Judge found that, after hearing the evidence, “Moreover, at no point during these occasions do I find that the mother withdrew consent or conveyed to the father any discomfiture that she was feeling about the intercourse continuing.”

Given that, I am unsurprised that the Judge found that it wasn’t rape and his main flaw seems to have been a stupid focus on force (which, I agree, is wrong) and bad phrasing. However, while the focus on physical force was wrong it was only one of the factors of the decision and, given the other factors, I can’t see that it would have made much difference to the result either way.

(17)(9)

Anon

Clearly neither of you twats has read the judgment. It’s not difficult – and then you won’t have to speculate about what you might see “if you actually read the judgment”.

Spoiler alert: it’s exactly what he says.

(19)(10)

Anon

Clearly you cannot read and, while I commiserate with your clear developmental disadvantage, I would point out that I have read the judgment (which should be quite evident from the fact that I am quoting parts of it above).

(12)(3)

Anon

It should be fairly evident that I read the judgment given that I am specifically quoting parts of it, you big silly.

(3)(3)

Anonymous

I haven’t read the judgement, but from the summaries I’ve seen and other comments her take on what she said seems skewed.

(2)(6)

#thetideisturning

@1.04pm. Quite. I’ve now read her judgment and it’s not impressive. Full of typos, terrible grammar (does the woman not know the difference between a full-stop and a comma?) and obviously written in a rage.

And as you point out, even Mx Justice Russell’s no doubt highly tendentious selection of passages from Tolson’s written ruling can’t disguise the fact that he found as a fact that the mother did not say “no”.

Tolson should certainly have expressed himself more carefully, especially now that Social Justice Screechers have infiltrated the High Court. But his conclusions are hardly an outrage.

(14)(16)

Anonymous

What does the ‘training’ involve and has Russell undergone it?

(7)(5)

Just Anonymous

I haven’t read the judgement in full. You can read it here and form your own view:

https://www.bailii.org/ew/cases/EWHC/Fam/2020/86.html

However, a few comments:

At [35], Russell J quotes the trial judge, who is summarising the parties’ respective contentions. In short, the woman was saying that they were initially having consensual sex, she told him to stop and he did not. The man said the sex was all consensual and he was never told to stop.

At [36], Russell J quotes the following passage from the trial judge, referring to the above sexual episode:

“My concern about this occasion centres on the idea that the mother did nothing physically to stop the father. In particular, given the position in which intercourse was occurring, because the mother was not in any sense pinned down on this occasion, but could easily, physically, have made life harder for the father. She did not do so. I do not find that the father was in any way on this occasion so physically forcing her as to cause her not to be able to take preventative measures, nor, in fact, is that case alleged. Following the event, as I have already said, the mother took no immediate action to report the matter to the police, or indeed to anyone else. Her description, of course, does not indicate that the circumstances were such that she might in any way have been thought wise to seek medical advice.”

Russell J assesses this in [37] as follows:

“This judgment is flawed. This is a senior judge, a Designated Family Judge, a leadership judge in the Family Court, expressing a view that, in his judgment, it is not only permissible but also acceptable for penetration to continue after the complainant has said no (by asking the perpetrator to stop)…”

In my conclusion, this conclusion is manifestly unfair and does not follow from what the trial judge said. Russell J’s analysis assumes as an established fact that the woman DID ask the man to stop. But the man disputed that. If the trial judge made a finding to that effect, Russell J did not quote it.

It is difficult to tell because Russell J does not quote the entirety of the relevant passages, but the trial judge could merely be concluding that the woman in fact did not ask the man to stop at all, and her physical behaviour was an evidential reason why he reached that conclusion. Put another way, the potential logic is “If this particular woman had told him to stop, I judge that she would have physically resisted/gone to the police. She did not do so. Thus, I conclude that she did not tell him to stop.”

That analysis could still be wrong on the particular facts of this case, and there could well be other genuine errors with the judge’s approach. But in my view, this particular attack from Russell J is unwarranted.

(23)(8)

Anonymous

Thanks, I don’t have time to read the full judgement, but your comment sounds sensible.

So, it looks like Tolson is saying that in this case the lack of physical resistance (assuming there was such lack) meant consent, not that lack of physical resistance always means consent. That would seem right. Russell seems to be saying that a lack of physical resistance never indicates consent which must be wrong.

(6)(3)

Anonymous

At [44], Russell explains: “The judge failed to explain the reasons for his findings; as to why, if it was evident to the judge that the Appellant had become averse to sexual intercourse continuing it was not evident to the Respondent; and, secondly, why it was acceptable for the Respondent to insist on sexual intercourse knowing that it was distressing and unwelcome to the Appellant. The evidence that the judge had rehearsed thus far did would not support such a finding nor did he give any or adequate reasons for preferring the evidence of the Respondent…”

Earlier on in the judgment, she also says that Tolson gave too much weight to demeanour in assessing the evidence of the parties.

I think the attack on Tolson and the generally aggressive tone of the judgment masks the possibly legitimate argument that Russell is making. She essentially is claiming that Tolson’s factual finding (that there was no lack of consent) was based too heavily on a lack of physical consent and the respective demeanours of the parties.

However, I think that this ultimately wrong, because Russell is essentially reversing the burden of proof.

Tolson thought that the demeanour of the parties and their sexual history supports a finding that there was no lack of consent on the occasions in question, while Russell is basically saying that there was not enough evidence to displace what appears prima facie (in her reckoning) to be rape.

That said, I am not an expert in this area, and the lack of the trial judgment text makes it very hard to say which is the better argument. Will be interesting to see what happens when this goes on appeal.

(9)(1)

Anon

But Russell appears to be saying that lack of physical resistance doesn’t imply consent at all, and would never imply consent, and that anyone who disagrees should be sent away for special ‘training’.

(3)(1)

Miranda Escobedo

Re claims above she did not say “no”/Tolson found she did not say “no”, see quotes from Tolson judgment (btw, in case this needs explaining, asking the person to stop is the same as saying “no”!);

@ Paragraph 23 [of T’s judgment] reads “…the first occasion it is the mother’s own case that sexual intercourse began with her consent, and consent was only removed during intercourse when the mother told the father to stop — but he failed to do so. The difficulties do not end there because this is a mother who very often, and for all I know, always, found that she had difficulties in taking physical enjoyment from sex. She would, she tells me, often tell the father to stop during the times when intercourse between them was more frequent than it was in 2016

Tolson judgment @ para 24 “…the sex in question took place with the mother kneeling on the bed and the father standing behind her. During intercourse she told him to stop, but he did not, and carried on at least for “a couple of minutes”, which is a description given, I think, to the police.”

(0)(0)

Anonymous

So it was claimed that she didn’t say no, and the judge found that she didn’t say no. The judge is allowed to make that decision, unless that is what people have a problem with.

(0)(0)

Anonymous

Surely Tolson said that lack of physical resistance was a factor in his decision on consent, not the sole reason, and surely this is a valid conclusion. Russell doesn’t appear to understand this.

(17)(5)

Anon

Russell should undergo training on the meaning of consent based on this.

(12)(5)

Anon

I’ve long thought there was an anti-male basis in the family courts, but hadn’t realised this extended even towards male judges.

(10)(12)

Anonymous

England is gold-digger paradise.

(5)(4)

Another Anon

After reading your thread it’s to be hoped that in the best interests of every woman in this country you don’t live in England or that you practise law.

(0)(0)

Anonymous

Which comments and why?

(0)(0)

Lizzo

All the Alt Right mugs are out in force in the comments it seems. Lack of physical resistance doesn’t mean there was consent. A first year undergraduate could tell you that. Put your fragile egos aside and take a secotto think about why you instantaneously jump to defend the male abuser rather than the victim.

(16)(19)

I See Fat People

Maybe you should read what is being said in the comments. You seem not to have done that, which is quite the leftist modus operandi. The comments review what was said by Tolson and conclude it was not as summarised by Russell.

(12)(4)

Miranda Escobedo

How could the comments KNOW what was said by Tolson apart from the quotes from his judgment (and summaries by Russell) in the appeal????

(0)(0)

Anonymous

And what people are saying are that the comments are reviewing Tolson’s quotes and concluding that they are not as summarised by Russell.

(0)(0)

lulzo

You’re losing the war lizzo!

(5)(1)

Traga

Ms Justice Russell. Private school, then Southbank Polytechnic. Must be a right brainbox.

(15)(6)

Anon

There is a real risk that this type of decision could intimidate judges into automatic guilty findings against those accused of rape, and a corresponding increase in innocent men being locked up. The judiciary should offer a robust clarification of Russell’s remarks and there needs to be balanced media coverage of this type of thing.

(7)(4)

Anonymous

Upping rape conviction rates is seen as a per se good by the feminist lobby. To thems ome innocent men must be convicted in the name of both justice and a misunderstanding of the relative difficulty of establishing certain offences to the accepted necessary criminal standards. Preventing access to evidence to use in a defence seems to be a way of achieving this. Heaven forbid that when balancing defending allegations that life changing against the annoyance of have to hand over an image of phone data, the annoyance is seen as the greater harm.

(16)(9)

Ms Law

Upping the rape conviction is not the aim. The aim is creating an environment where victims of rape can report the crime and can give their best evidence at court by being afforded special measures. This in turn will lead to offenders who are guilty of rape being convicted. The current state of our legal system is that victims do not come forward through fear of facing their rapist and reliving their ordeal only for the offender to be found not guilty.

No one wants innocent men in prison; that is not beneficial to society.

Society should want the following;

1. People to stop raping;
2. Victims of rape to be able to report the offence and give evidence in court with as much assistance as is necessary; and
3. For rapists to be convicted of their crime.

I fear you miss the point of the judgment in question given it was a fact finding trial in a family court rather than a criminal trial. Further all the appeal judge stated was that the comments made of the trial judge was not in alignment with the criminal law on consent. Everything the appeal judge stated is the current state of the criminal law on consent.

So in short, her comments alone will not “up” the conviction rate of innocent men.

(3)(4)

Anonymous

Preventing access to evidence that assists with the defence and impeding the ability of the accused to challenge evidence are both matters that increase the prospects of wrongful conviction. That these measures somehow assuage an alleged reticence of reporting is just not good enough. Why should rape trials, serious as they are, not be subject to the basic defendant rights and protections as required in other criminal matters? There are other ways to address this alleged problem, such as improving reporting processes and supportive counseling that do not require any interference with established protective norms.

As to your numbered points:

1. No procedural reform is going to material affect the incidence of rape or alleged rape.
2. To the extent there is an issue, the matter can be dealt with by other processes and does not need to undermine fair due process for the accused. The constant chipping away of standard processes is already risking increased rates of wrongful convictions.
3. Is intellectually dishonest. We accept across the criminal litigation process that protections against wrongful convictions mean that many guilty persons walk free. One cannot pick and choose what offences we are willing to undermine that protection and convict innocent people. Your logic demands a longer form version of point thee “3. For rapists to be convicted of their crime by reforms that will also lead to increased rates wrongful convictions against men.” You cannot ignore the inevitable consequences of the pressure to increase conviction rates.

To achieve your aims you must accepting that the innocent will be convicted when they would not otherwise be convicted. Are you at least happy to admit that is price you are happy to impose on others as a result of the changes you support?

(2)(4)

Ms Law

Absolutely incorrect. Once again I must reiterate the case you are referring to is a family law matter, not a criminal one.

Furthermore special measure are in place to allow vulnerable victims to give their best evidence. There is no denial of the accused’s rights. The accuser gave evidence and the accused was entitled to put questions to her regarding the same. The respondent simply asked for a screen so as not to be intimated by her abuser. This is common practice with vulnerable witnesses and strikes the balance of ensuring a vulnerable witness can give their best evidence and that an accused can question their accuser.

Further had you read the judgment you would have not only noted that the respondent was denied these special measures but also that the applicant was then allowed “help” during this cross examination which is wholly inappropriate. The vulnerable party here was put at a disadvantage not the applicant.

I do not accept special measures result in more innocent people being convicted. In fact the evidence suggests otherwise with rape convictions being at an all time low.

In my view it is not only the judiciary that need training is sexual offences but the wider legal profession given the comments on this thread. This is basic criminal law 101.

I personally think that consent should be taught during sex education. Society needs to have a better understanding of consent.

All of the above would make my points 1-3 possible without increasing prosecution and conviction of innocent people.

(3)(0)

Anonymous

I think everyone, including Russell should attend the training that she is so readily recommending to others in order to get a better understanding of what consent is.

nemo

[2017] EWCA Civ 237 makes interesting reading

“……Although I regret the need to make such a finding about any High Court judge, I consider that Russell J’s errors did amount to “gross and obvious irregularity”‘

(7)(0)

Anon

She is a very poor judge. Not up to it intellectually or temperamentally.

(9)(3)

Anonymous

This was less a judgement and more a political statement.

(5)(2)

Miranda Escobedo

Have you read the judgment?

(0)(0)

Anonymous

Which one?

(0)(0)

Anonymous

There’s a whiff of misandry about this – its beginning to look as this has been orchestrated with Tolson as a pasty to scare male judges off from finding rape defendants not guilty.

(5)(18)

Ms Law

This wasn’t a criminal case. It was a fact finding trial in a family law matter. The applicant wouldn’t have been found “guilty” of rape. The trial judge would’ve simply concluded on the balance of probability the rape did happen and take the same into consideration when making a child arrangement order.

(5)(2)

Anonymous

Ok, the whiff of misandry arises from what looks like an orchestrated attempt (with Tolson as a patsy) to intimidate male judges into concluding on the balance of probability the rape did happen and take the same into consideration when making a child arrangement order, even if they didn’t genuinely believe that it did.

(2)(1)

Ms Law

The decision for a retrial is absolutely the correct one. The trial judge made a whole host of procedural errors which I consider led to the flawed conclusion.

In my view, the judge erred in not allowing special measures to the respondent without reasoning his decision. The fact that there was allegations of domestic violence collaborated by contemporaneous police reports warranted the respondent having the special measures she sought. The trial judge’s decision led to the respondent being unable to give her best evidence and contributed to the anxious demeanour, which the trial judge then used against her in his fact finding.

Not only did the judge’s decisions put the respondent at a disadvantage, he proceeded to then put the applicant in a further advantageous position by allowing a Mckenzie friend to assist him whilst giving his evidence.

In these circumstances the trial judge did not put the parties on an equal playing field. Rather he flew in the face of the FPR by making the trial process harder for a vulnerable party. Given the bias which the judge showed in his decision making (we can only assume it was bias given the trial judge did not explain his reasoning as he is required to) it is hardly surprising that he found the applicant to be more credible than the respondent. This is especially unsurprising given the trial judge confessed he could not hear much of what the respondent said when giving her evidence.

The appeal judge stated that the above alone was enough to warrant a retrial and I quite agree. The decision to deny the special measures along with the lack of reasoning behind the decision are procedural irregularities requiring retrial.

The comments the trial judge made regarding consent are concerning. They are not in alignment with the current jurisprudence.

It cannot be suggested that if a woman does not physically resist she is giving consent. We are all familiar with the concept of “fight or flight”. Some people freeze and so are unable to physically resist.

It appears in this case the trial judge found, in relation to the first allegation of rape, that intercourse started out as consensual but that the respondent became adverse to sex whilst the parties were already intimate. The way in which the trial judge communicated his reason for finding the respondent did not withdraw consent is because she did not “make it difficult for him”. The wording used by the trial judge create the impression that women have to take some physical step to withdraw consent. That is a dangerous precedent. It implies that unless a victim gives evidence along the lines of “I told him no AND pushed him off” that the facts will not support a finding of rape.

In light of the judges comments, I do consider a retrial is necessary. Further, it can only be beneficial for the judiciary to have training on consent and how to handle fact finding trials where sexual allegations are made to avoid clumsy comments like this in the future.

(5)(13)

Anonymous

There may well have been procedural errors, but they happen in cases up and down the country every day, not just in sexual matters. Its unclear why Russell and the media jumped on this one unless it was to push an agenda.

The judge has a responsibility to allow both parties to give evidence freely, not just the female. That is something the family courts don’t always get.

The judge, as he is entitled to do, took the view that in this case lack of physical resistance meant consent, and he was right. He never said that lack of physical resistance always means consent, but his words have been seized upon and twisted by those with an agenda to make out that this is what he said. The reality is that in the vast majority of cases where consent is not given there will be physical resistance. There will be cases where there is not, but these will be a minority.

Training on consent is important, and it is is imperative that Russell attend such training before sitting on any other cases which will will give her the opportunity to launch the type of ill-informed tirade which we saw in the recent judgement.

(2)(1)

Me

“The reality is that in the vast majority of cases where consent is not given there will be physical resistance. There will be cases where there is not, but these will be a minority.”

Where are you getting this assertion from? It is well documented that victims of rape will often freeze and not put up any form of physical resistance.

(1)(0)

Anonymous

I wouldn’t agree it happens often, although it does happen. But physical resistance is much more common than not.

(0)(1)

Me

Again where are you getting your evidence for this assertion from? It seems to be this is just your opinion

(0)(0)

Anonymous

It’s an opinion based on how people react to things. Are you arguing that the majority of rape victims don’t physically resist?

Dave Potts

A silly debate about the title of a judge, comments of a judges spelling errors etc, these are trivial issues, compared to a judge being in effect told in effect he did not understand the law and that should be regarded as a major problem for a judge

(0)(0)

Anon

If he was right and was attacked because of his gender (as I believe he was), it’s a problem for us all.

(0)(1)

Anonymous

It is starting to look like Tolson is the victim of a co-ordinated attack between elements of the judiciary, media and political interest groups. What he said has been deliberately misinterpreted (he didn’t say that physical resistance is always necessary to show that consent wasn’t given, only that in this case he felt that the lack of physical resistance was a factor). If what is being argued is that lack of physical resistance should be completely ignored in all cases, this is frankly bonkers and will lead to a substantial increase in miscarriages of justice.

This is an attempt to intimidate judges into finding men accused of rape automatically guilty and in reducing mens’ input into the already biased family courts. In the interest of balance at the very least, it would be good to see members of the judiciary and the media defending Tolson and criticising Russell.

(1)(1)

Me

“The reality is that in the vast majority of cases where consent is not given there will be physical resistance. There will be cases where there is not, but these will be a minority.”

Where are you getting this assertion from? It is well documented that victims of rape will often freeze and not put up any form of physical resistance.

(0)(0)

Anonymous

I wouldn’t say it happens often, although it does happen. But physical resistance is much more common than not.

(0)(0)

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