House of Lords - Regina v. K     
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      Judgments - Regina v. K 
      HOUSE OF LORDS
      Lord Bingham of Cornhill Lord Nicholls of Birkenhead Lord Steyn Lord 
      Hobhouse of Wood-borough Lord Millett 
      OPINIONS OF THE LORDS OF APPEAL FOR JUDGMENT
      IN THE CAUSE
      REGINA
      v
      K
      (APPELLANT)
      (ON APPEAL FROM THE COURT OF APPEAL (CRIMINAL DIVISION))
      ON 25 JULY 2001
      [2001] UKHL 41
      LORD BINGHAM OF CORNHILL
      My Lords,
          1. The appellant K was indicted on a single count of indecent assault 
      committed against a girl C who at the time was aged 14, contrary to 
      section 14(1) of the Sexual Offences Act 1956. His defence was to be that 
      the sexual activity between him and C was consensual, that she had told 
      him she was 16 and that he had had no reason to disbelieve her. He is a 
      man of good character, aged 26 at the date of the offence charged against 
      him. Before the trial a preliminary issue was raised on behalf of K: 
      whether, to establish K's guilt under the section, the prosecution had to 
      prove that at the time of the incident K did not honestly believe that C 
      was 16 or over. Argument on this issue was heard by his Honour Judge 
      Thorpe at the Chichester Crown Court. He ruled, in favour of K, that the 
      prosecution did have to prove an absence of genuine belief on the part of 
      the accused that the victim was aged 16 or over. In so ruling the judge 
      relied on the recent decision of the House of Lords in B (A Minor) v 
      Director of Public Prosecutions [2000] 2 AC 428. The prosecution appealed 
      against that ruling under section 35 of the Criminal Procedure and 
      Investigations Act 1996. The Court of Appeal (Criminal Division) (Roch LJ, 
      Rougier and Gray JJ) allowed the appeal and held that such absence of 
      genuine belief did not have to be proved. The court certified the 
      following point of law of general public importance:
        "(a)  Is a defendant entitled to be acquitted of the offence of indecent 
        assault on a complainant under the age of 16 years, contrary to section 
        14(1) of the Sexual Offences Act 1956, if he may hold an honest belief 
        that the complainant in question was aged 16 years or over?
        (b)  If yes, must the belief be held on reasonable grounds?"
      Leave to appeal was refused by the Court of Appeal but granted by the 
      House.
          2. Section 14 of the 1956 Act is in these terms:
        "(1)  It is an offence, subject to the exception mentioned in subsection 
        (3) of this section, for a person to make an indecent assault on a 
woman.
        (2)  A girl under the age of sixteen cannot in law give any consent 
        which would prevent an act being an assault for the purposes of this 
        section.
        (3)  Where a marriage is invalid under section two of the Marriage Act, 
        1949, or section one of the Age of Marriage Act, 1929 (the wife being a 
        girl under the age of sixteen), the invalidity does not make the husband 
        guilty of any offence under this section by reason of her incapacity to 
        consent while under that age, if he believes her to be his wife and has 
        reasonable cause for the belief.
        (4)  A woman who is a defective cannot in law give any consent which 
        would prevent an act being an assault for the purposes of this section, 
        but a person is only to be treated as guilty of an indecent assault on a 
        defective by reason of that incapacity to consent, if that person knew 
        or had reason to suspect her to be a defective."
      This section is matched by a parallel section, section 15, which makes it 
      an offence for a person to make an indecent assault on a man. Subsections 
      (2) and (3) of section 15 are to the same effect, in relation to men, as 
      subsections (2) and (4) in relation to women.
          3. If the provisions of section 14 were part of a single, coherent 
      legislative scheme and were read without reference to any overriding 
      presumption of statutory interpretation, there would be great force in the 
      simple submission which Mr Scrivener, resisting this appeal on behalf of 
      the crown, based upon them: subsections (3) and (4) define circumstances 
      in which a defendant's belief, knowledge or suspicion exonerate a 
      defendant from liability for what would otherwise be an indecent assault; 
      if it had been intended to exonerate a defendant who believed a 
      complainant to be 16 or over, this ground of exoneration would have been 
      expressed in subsection (2); the omission of such a provision makes plain 
      that no such ground of exoneration was intended.
          4. It is, however, plain that section 14 was not part of a single, 
      coherent legislative scheme. The 1956 Act was a consolidation Act. Its 
      provisions derived from diverse sources. The rag-bag nature of the 1956 
      Act and its predecessor statutes has been the subject of repeated comment: 
      see, for example, the observations of the draftsman of the 1861 Act quoted 
      in B (A Minor) v Director of Public Prosecutions [2000] 2 AC 428, 473D; 
      the criticisms of Lord Nicholls of Birkenhead in the same case, at p 465G; 
      the description of the Act by Professor Lacey as "a patchwork of 
      pre-existing offences" in [2001] Crim LR 3, at p 3; the recognition of the 
      Home Office in "Setting the Boundaries, Reforming the law on sex offences" 
      (July 2000, vol 1, para 3.2.3) that the present legislation "does not form 
      a coherent code".
          5. Section 14(1) derives from section 52 of the Offences against the 
      Person Act 1861. At common law there was no offence of indecent assault. 
      Section 52 of the 1861 Act criminalised "any indecent assault upon any 
      female". The maximum penalty was two years' imprisonment. Since conduct is 
      not generally an assault in law if done with the consent of the alleged 
      victim, it seems clear that the consent of the victim, whatever her age, 
      defeated a charge under this section as originally enacted.
          6. Plainly this provision gave inadequate protection to children, 
      whose inherent immaturity was understandably regarded as impairing any 
      consent they might give. There was legitimate public concern when a 
      defendant accused of indecently assaulting a child of 6 years relied 
      successfully on the consent of the child. There could have been no belief 
      on the defendant's part that the child was over the age of consent, so 
      that issue did not arise. In the Criminal Law Amendment Act 1880 (43 & 44 
      Vict, c45) it was provided that it should be no defence to a charge of 
      indecent assault on a young person under the age of 13 to prove that he or 
      she consented to the act of indecency. This provision was re-enacted in 
      section 1 of the Criminal Law Amendment Act 1922 (with an increase of the 
      age to 16). It is the source of section 14(2).
          7. Until 1929 England and Wales adhered to the old canon law rule that 
      boys could be married at 14 and girls at 12. The Age of Marriage Act of 
      that year provided that a marriage between persons either of whom was 
      under the age of 16 should be void. This enactment was subject to a 
      proviso that in any proceedings against a person charged under section 
      5(1) of the Criminal Law Amendment Act 1885 (48 & 49 Vict, c69) or with 
      indecent assault it should be a sufficient defence to prove that at the 
      time when the offence was alleged to have been committed he had reason to 
      believe that the alleged victim was his wife. This proviso was repealed by 
      the Marriage Act 1949 (which re-enacted the age limit) but the repeal was 
      itself repealed in 1953. Section 14(3) thus derives from sources quite 
      different from the other provisions of the 1956 Act with which the House 
      is concerned.
          8. Section 14(4) derives from section 56(3) of the Mental Deficiency 
      Act 1913 which provided that no consent should be any defence in any 
      proceedings for an indecent assault upon any defective, if the accused 
      knew or had reason to suspect that the person in respect of whom the 
      offence was committed was a defective.
          9. Since the 1956 Act was a consolidation Act, with corrections and 
      improvements to the expression but not to the substance of existing 
      provisions (see generally Halsbury's Laws of England, 4th ed reissue, vol 
      44(1) (1995), para 1247), it is not surprising that the terms of section 
      14 reflected their miscellaneous origins. But that section cannot properly 
      be considered in isolation. Section 50 of the 1861 Act made unlawful 
      carnal knowledge of a girl under the age of 10 a felony punishable by 
      penal servitude for life. Section 51 made unlawful carnal knowledge of a 
      girl aged 10 or 11 a misdemeanour punishable by up to three years' penal 
      servitude. It was these sections to which Blackburn J, with the 
      concurrence of nine other judges, referred in the course of his ruling in 
      R v Prince (1875) LR 2 CCR 154, 171-172 that for purposes of section 55 of 
      the 1861 Act it was no defence for a defendant charged with taking an 
      unmarried girl under the age of 16 out of the possession of her father to 
      establish a reasonable belief that she was over 16:
        "It seems impossible to suppose that the intention of the legislature in 
        those two sections could have been to make the crime depend upon the 
        knowledge of the prisoner of the girl's actual age. It would produce the 
        monstrous result that a man who had carnal connection with a girl, in 
        reality not quite ten years old, but whom he on reasonable grounds 
        believed to be a little more than ten, was to escape altogether. He 
        could not, in that view of the statute, be convicted of the felony, for 
        he did not know her to be under ten. He could not be convicted of the 
        misdemeanour, because she was in fact not above the age of ten. It seems 
        to us that the intention of the legislature was to punish those who had 
        connection with young girls, though with their consent, unless the girl 
        was in fact old enough to give a valid consent. The man who has 
        connection with a child, relying on her consent, does it at his peril, 
        if she is below the statutable age."
          10. But the law did not rest there. By section 5 of the Criminal Law 
      Amendment Act 1885 it was provided that:
        "Any person who - 
        (1) Unlawfully and carnally knows or attempts to have unlawful carnal 
        knowledge of any girl being of or above the age of thirteen years and 
        under the age of sixteen years; or . . .
        shall be guilty of a misdemeanour, and being convicted thereof shall be 
        liable at the discretion of the court to be imprisoned for any term not 
        exceeding two years, with . . . 
        Provided that it shall be a sufficient defence to any charge under 
        sub-section one of this section if it shall be made to appear to the 
        court or jury before whom the charge shall be brought that the person so 
        charged had reasonable cause to believe that the girl was of or above 
        the age of sixteen years."
      A similar provision based on reasonable belief that a girl was of or above 
      the age of 16 was included in section 6 of this Act. Thus, despite the 
      view of the strong majority in R v Prince, a potential defence based upon 
      belief as to age was expressly introduced. This defence was significantly 
      modified by section 2 of the Criminal Law Amendment Act 1922, which 
      provided:
        "Reasonable cause to believe that a girl was of or above the age of 
        sixteen years shall not be a defence to a charge under sections five or 
        six of the Criminal Law Amendment Act 1885 . . . Provided that in the 
        case of a man of twenty-three years of age or under the presence of 
        reasonable cause to believe that the girl was over the age of sixteen 
        years shall be a valid defence on the first occasion on which he is 
        charged with an offence under this section."
      Thus was introduced what came to be known as the statutory or young man's 
      defence. The slipshod drafting of the section is evident from its closing 
      words since section 2 created no offence with which any defendant could 
      ever be charged. But the section gave rise to a much more fundamental 
      anomaly. If a defendant was charged under section 5(1) with the very 
      serious offence of having unlawful carnal knowledge of a girl aged between 
      13 and 16, the statutory defence was potentially open to a man of 23 or 
      under charged for the first time. If, however, the man was charged with 
      the lesser offence of indecently assaulting a child or young person under 
      the age of 16 (an offence inevitably committed if he had intercourse with 
      her), there was no express provision enabling the defendant to rely on an 
      honest belief that the child or young person was over the age of 16.
          11. It was not long before this anomaly became apparent. In R v Forde 
      [1923] 2 KB 400 a young man, under the age of 23, had intercourse with a 
      15 year-old girl. He was charged with offences against section 5(1) of the 
      1885 Act and section 52 of the 1861 Act, both offences relating to the 
      same act of intercourse. He pleaded not guilty to the first (more serious) 
      offence but guilty to the second and was bound over. It was found as a 
      fact that he had had reasonable cause to believe that the girl was over 16 
      and the charge under section 5 was not proceeded with. He appealed by 
      leave of the trial judge, and it was argued that, to avoid absurdity, the 
      statutory defence should be available in relation to the indecent assault 
      charge as well as the carnal knowledge charge, where the indecent assault 
      was the act of carnal knowledge. Counsel for the crown did not contend 
      that the result of the statute was not absurd but said the law was clear. 
      The Court of Criminal Appeal upheld the conviction. Giving the judgment of 
      the court Avory J said, at p 404:
        "The words of a statute cannot be construed, contrary to their meaning, 
        as embracing cases merely because no good reason appears why those cases 
        should be excluded. It is not the duty of the Court to make the law 
        reasonable, but to expound it as it stands, according to the real sense 
        of the words. Applying that principle, we can find no justification for 
        reading the proviso to s.2 of the Act, which in terms is limited to 
        charges of offences under that section, as applicable to a charge of 
        indecent assault, which is separately dealt with in s.1. It is only by a 
        benevolent construction that any effect can be given to this proviso, 
        seeing that no offence is created by s.2, but if it be assumed to apply 
        to charges under ss.5 or 6 of the Criminal Law Amendment Act, 1885, 
        which are referred to in the earlier part of the section, there is no 
        canon of construction which would justify the Court in applying it to 
        s.1, bearing in mind the various forms of indecent assault which do not 
        amount to carnal knowledge."
          12. In R v Laws (1928) 21 Cr App R 45 the defendant had intercourse 
      with a girl aged 15 years and 9 months. He was about a year older. He 
      could rely on the statutory defence to a charge laid against him under 
      section 5 of the 1885 Act, but pleaded guilty to a count of indecent 
      assault arising out of the same incident. Lord Hewart CJ, at p 46, 
      described it as "a grotesque state of affairs that the law offers a 
      defence upon the major charge, but excludes that defence if the minor 
      charge is preferred". But the conviction was upheld. The defendant's 
      sentence of four months' imprisonment was reduced to a nominal sentence of 
      one day.
          13. The defendant in R v Keech (1929) 21 Cr App R 125 was aged 21 at 
      the relevant time. He had intercourse with a girl under the age of 16 and 
      faced counts of unlawful carnal knowledge and indecent assault, the facts 
      relied on in relation to both sets of counts being the same. The mother of 
      the victim gave evidence that at the time of the relevant events the girl 
      looked 18, and but for the recent increase in the minimum age of marriage 
      the two would have been married. The defendant was acquitted on the carnal 
      knowledge count, no doubt in reliance on the statutory defence, but was 
      convicted on the indecent assault count. The 1922 Act was again described 
      as "grotesque" (at p 128) and the legislation was described by Lord Hewart 
      CJ as "amazing" (p 131). But the conviction was upheld and the sentence of 
      one month's imprisonment reduced to one day, which permitted the immediate 
      discharge of the defendant.
      14. 
          R v Maughan (1934) 24 Cr App R 130 repeated the story. The defendant 
      was aged 22, the child between 13 and 16. There were six counts, three of 
      carnal knowledge, three of indecent assault, arising from the same facts. 
      He was acquitted on the carnal knowledge counts, plainly because he made 
      good the statutory defence. He was convicted on the three counts of 
      indecent assault. On appeal, with the certificate of the trial judge, it 
      was argued that the defendant could rely on a defence of mistaken fact 
      based on the child's age. Despite the "apparent absurdity resulting from 
      this state of legislation" (at p 133) the appeal was dismissed. But the 
      trial judge had passed a nominal sentence of two days' imprisonment to run 
      from the first day of the assizes and this resulted in the immediate 
      discharge of the defendant.
          15. Since the 1956 Act was a consolidation Act, there was no 
      opportunity to correct this apparent absurdity. Section 5 of this Act 
      again made it a felony to have unlawful sexual intercourse with a girl 
      under the age of 13. Section 6 as enacted again made it an offence, 
      subject to the exceptions in the section, for a man to have unlawful 
      sexual intercourse with a girl not under the age of 13 but under the age 
      of 16. One of the exceptions, in subsection (2), corresponded to the 
      invalid marriage exception in section 14(3). The second exception, in 
      subsection (3), reproduced the statutory or young man's defence. Thus the 
      anomaly highlighted by the cases cited above was perpetuated. Asked to 
      suggest any reason why it could rationally have been intended to provide 
      the statutory defence where full intercourse took place and no defence 
      based on belief as to the child's age when intercourse was charged as 
      indecent assault, leading counsel for the crown in the present appeal was 
      unable to assist, as his predecessor in R v Forde had been in 1923.
          16. Even before enactment of the 1956 Act, a lacuna in the existing 
      legislation had come to light. In both Fairclough v Whipp [1951] 2 All ER 
      834 and Director of Public Prosecutions v Rogers [1953] 1 WLR 1017 there 
      had been objectionable acts of indecency, in the first case involving an 
      adult man and a child of nine, in the second a father and his eleven 
      year-old daughter. But in neither case had there been an assault since the 
      child had, at the adult's invitation, touched him, albeit indecently. 
      Following a report of the Criminal Law Revision Committee in 1959 (Cmnd 
      835) Parliament enacted the Indecency with Children Act 1960 which in 
      section 1(1) provided:
        "Any person who commits an act of gross indecency with or towards a 
        child under the age of fourteen, or who incites a child under that age 
        to such an act with him or another, shall be liable on conviction on 
        indictment to imprisonment for a term not exceeding two years, . . ."
      In B (a Minor) v Director of Public Prosecutions [2000] 2 AC 428 the issue 
      was whether, under that section, it was necessary for the prosecution to 
      prove the absence of a genuine belief on the part of the defendant that 
      the child was over the specified age of 14. The House (Lord Irvine of 
      Lairg LC, Lord Mackay of Clashfern, Lord Nicholls of Birkenhead, Lord 
      Steyn and Lord Hutton) unanimously held that it was.
          17. In reaching this conclusion the House relied on
        "the established common law assumption that a mental element, 
        traditionally labelled mens rea, is an essential ingredient unless 
        Parliament has indicated a contrary intention either expressly or by 
        necessary implication. The common law presumes that, unless Parliament 
        has indicated otherwise, the appropriate mental element is an 
        unexpressed ingredient of every statutory offence" (per Lord Nicholls of 
        Birkenhead, at p 460F). 
      Lord Steyn, at p 470F, quoting from Professor Sir Rupert Cross, referred 
      to the presumption that mens rea is required in the case of all statutory 
      crimes, a presumption operating as a constitutional principle and not 
      easily displaced by a statutory text. Crucial to the conclusion of the 
      House was the now classic statement of principle in the speech of Lord 
      Reid in Sweet v Parsley [1970] AC 132, 148-150. The speech is too well 
      known to require extensive citation; brief extracts will suffice:
        ". . . there has for centuries been a presumption that Parliament did 
        not intend to make criminals of persons who were in no way blameworthy 
        in what they did. That means that whenever a section is silent as to 
        mens rea there is a presumption that, in order to give effect to the 
        will of Parliament, we must read in words appropriate to require mens 
        rea" (at p148G).
        ". . . it is firmly established by a host of authorities that mens rea 
        is an essential ingredient of every offence unless some reason can be 
        found for holding that that is not necessary" (at p 149C).
      The general rule that a crime involves a guilty mind as well as a 
      forbidden act is, as the Latin version of the rule makes clear and as Lord 
      Reid emphasised, of very long standing. Brett J in his dissenting judgment 
      in R v Prince (1875) LR 2 CCR 154 referred to it at pp 159-169, 
      concluding, at p169: 
        "Upon all the cases I think it is proved that there can be no conviction 
        for crime in England in the absence of a criminal mind or mens rea."
      In R v Tolson (1889) 23 QBD 168 Stephen J, an authority on the criminal 
      law without rival in his time, observed, at p 187:
        "The mental element of most crimes is marked by one of the words 
        'maliciously', 'fraudulently', 'negligently', or 'knowingly', but it is 
        the general - I might, I think, say, the invariable - practice of the 
        legislature to leave unexpressed some of the mental elements of crime. 
        In all cases whatever, competent age, sanity, and some degree of freedom 
        from some kinds of coercion are assumed to be essential to criminality, 
        but I do not believe they are ever introduced into any statute by which 
        any particular crime is defined."
      In Sherras v De Rutzen [1895] 1 QB 918, 921 Wright J held:
        "There is a presumption that mens rea, an evil intention, or a knowledge 
        of the wrongfulness of the act, is an essential ingredient in every 
        offence; but that presumption is liable to be displaced either by the 
        words of the statute creating the offence or by the subject-matter with 
        which it deals . . ."
      He then went on to give examples of regulatory provisions which excluded 
      the presumption of mens rea. In Brend v Wood (1946) 62 TLR 462 Lord 
      Goddard CJ re-stated the rule, at p 463:
        "It should first be observed that at common law there must always be 
        mens rea to constitute a crime; if a person can show that he acted 
        without mens rea that is a defence to a criminal prosecution. There are 
        statutes and regulations in which Parliament has seen fit to create 
        offences and make people responsible before criminal Courts although 
        there is an absence of mens rea, but it is certainly not the Court's 
        duty to be acute to find that mens rea is not a constituent part of the 
        crime. It is of the utmost importance for the protection of the liberty 
        of the subject that a Court should always bear in mind that unless a 
        statute, either clearly or by necessary implication, rules out mens rea 
        as a constituent part of a crime, the Court should not find a man guilty 
        of an offence against the criminal law unless he has a guilty mind."
      Although in a minority, Lord Reid in R v Warner [1969] 2 AC 256 
      anticipated much of what he was to say, authoritatively, in Sweet v 
      Parsley. Later, expression was given to the presumption by, among others, 
      Lord Scarman in Gammon (Hong Kong) Ltd v Attorney-General of Hong Kong 
      [1985] AC 1, 14. Thus the rule is not of recent growth, although it has at 
      times been neglected. As Lord Reid observed in Sweet v Parsley, at p 150:
        "But I regret to observe that, in some recent cases where serious 
        offences have been held to be absolute offences, the court has taken 
        into account no more than the wording of the Act and the character and 
        seriousness of the mischief which constitutes the offence."
          18. The rule that a person under the age of 16 could not in law 
      consent to what would otherwise be an indecent assault led to the 
      description of an offence under section 14(1) or 15(1) against a victim 
      under the age of 16 as an absolute offence or an offence of strict 
      liability. These descriptions were a misnomer. There always had to be such 
      deliberation in the conduct of the defendant as would be necessary to 
      prove an assault. But the need for mens rea in a fuller sense was made 
      clear by the Court of Appeal (Criminal Division) (Lawton LJ, Michael 
      Davies and Sheldon JJ) in R v Kimber [1983] 1 WLR 1118. In that case the 
      charge was one of indecent assault contrary to section 14(1) of the 1956 
      Act and the victim was an adult. The recorder directed the jury that the 
      sole issue for their consideration was whether the victim had given her 
      real and genuine consent, adding that it did not matter whether the 
      defendant believed or thought she was consenting. This was held to be a 
      misdirection, at pp 1121E-1122A:
        "The offence of indecent assault is now statutory: see section14 of the 
        Sexual Offences Act 1956. The prosecution had to prove that the 
        appellant made an indecent assault on Betty. As there are no words in 
        the section to indicate that Parliament intended to exclude mens rea as 
        an element in this offence, it follows that the prosecution had to prove 
        that the appellant intended to commit it. This could not be done without 
        first proving that the appellant intended to assault Betty. In this 
        context assault clearly includes battery. An assault is an act by which 
        the defendant intentionally or recklessly causes the complainant to 
        apprehend immediate, or to sustain, unlawful personal violence: see Reg 
        v Venna [1976] QB 421, 428-429. In this case the appellant by his own 
        admissions did intentionally lay his hands on Betty. That would not, 
        however, have been enough to prove the charge. There had to be evidence 
        that the appellant had intended to do what he did unlawfully. When there 
        is a charge of indecent assault on a woman, the unlawfulness can be 
        proved, as was sought to be done in Reg v Donovan
        [1934] 2 KB 498, by evidence that the defendant intended to cause bodily 
        harm. In most cases, however, the prosecution tries to prove that the 
        complainant did not consent to what was done. The burden of proving lack 
        of consent rests upon the prosecution: see Reg v May [1912] 3 KB 572, 
        575, per Lord Alverstone CJ. The consequence is that the prosecution has 
        to prove that the defendant intended to lay hands on his victim without 
        her consent. If he did not intend to do this, he is entitled to be found 
        not guilty; and if he did not so intend because he believed she was 
        consenting, the prosecution will have failed to prove the charge. It is 
        the defendant's belief, not the grounds on which it was based, which 
        goes to negative the intent."
          19. In B (A Minor) v Director of Public Prosecutions [2000] 2 AC 428 
      the House considered section 1(1) of the 1960 Act in the light of the 
      presumption that guilty knowledge is an essential ingredient of a 
      statutory offence unless it is shown to be excluded by express words or 
      necessary implication. It found no express words and no necessary 
      implication having that effect. It was accordingly necessary for the 
      prosecution to prove the absence of a genuine belief on the part of the 
      defendant, whether reasonable or not, that the victim had been 14 or over. 
      The House was invited in that case (see pp 457G, 473A) to treat the Acts 
      of 1956 and 1960 as part of a single code, and that approach seems to me 
      to be plainly correct. It is at once obvious that if an absence of genuine 
      belief as to the age of an under-age victim must be proved against a 
      defendant under section 1 of the 1960 Act but not against a defendant 
      under section 14 of the 1956 Act, another glaring anomaly would be 
      introduced into this legislation. But that conclusion does not relieve the 
      House of the need to carry out, in relation to section 14, the task that 
      it carried out in relation to section 1.