LAW

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Kembaraxtra-Case Law- Larter and Castleton (1995)

Citation: Larter and Castleton (1995) (Court of Appeal - CA)
Subject: Definition of Consent in Rape Cases
Facts:
  • Two defendants convicted of raping a 14-year-old girl.
  • Victim claimed to be asleep during the rape and unaware of the act.
  • Defendants argued the judge should have directed the jury that the prosecution needed to prove either:
    • The victim physically resisted.
    • The victim was incapacitated and unable to make a conscious decision regarding consent.
Issue:
  • What constitutes the legal definition of "absence of consent" in rape cases?
  • What are the elements to prove absence of consent?
Holding:
  • The essential element of rape is the absence of consent.
  • Absence of consent should be given its ordinary meaning.
  • There is a crucial distinction between consent and submission.
  • Every consent involves a submission, but mere submission does not necessarily involve consent.
Key Takeaways/Significance:
  • This case clarifies that the focus in rape cases is on the absence of consent, not solely on resistance.
  • It emphasizes that the jury must understand the everyday meaning of consent.
  • It establishes that passivity or submission is not equivalent to consent. The prosecution must prove the victim did not consent.
  • This case highlights the importance of distinguishing between genuine consent and mere acquiescence due to fear, coercion, or other factors that negate free will.
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