Supporters of this view commonly contrast Brown with R v Wilson QB 47 which involved heterosexual sadomasochistic activity, though a different act from those in Brown, which was found lawful only a few years later by the Court of Appeal. The judgment has received criticism in some academic circles because, it is thought, if the facts had been different and involved heterosexual sadomasochistic activity it would have been found lawful. The House of Lords, by a 3–2 majority, decided that the consensual infliction of harm on another person for sexual gratification was not an act the law should permit. R v Brown 1 AC 212 is a case most law students could tell you the facts of even years after graduating, so remarkable are they.
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