The Representation of the Body in British Rape Trials

Sue Lees (1997)

A revised version of this article appeared in Ruling Passions published in 1997 by Open University Press


Issues of sexuality and the body have political significance, according to Foucault (1980:125) since sex is located at the point of intersection of the discipline of the body and the control of populations. As Smart points out (1987:92) women's bodies are legally significance because they are the site of biological reproduction, and therefore touch on issues concerning inheritance and legitimacy. To achieve this, the law both draws heavily on medical knowledge of the body to establish legal questions and control. In this chapter, I show how the portrayal of women in rape trials reflects myths that are rooted in medical discourses about the nature of women's bodies and of female sexuality, embedded in religious, moral and philosophical beliefs which can be seen to exert control over the court proceedings. Such evidence is used to contest the woman's testimony and caste doubt on her credibility. 

Foucault (1991: 106) outlines in the History of Sexuality how in the seventeenth century the deployment of alliance, by which he meant the system of marriage and kinship ties, was superseded, as a result of economic and political changes that rendered such ties less stable, by a new apparatus which he referred to as the deployment of sexuality. This involved the development of discourses of power and control, often emanating from the newly developing disciplines of psychology and medicine, over the human body. As a result, Foucault argued, the law 'operates more and more as a norm, and that the judicial institution is increasingly incorporated into a continuum of apparatuses (medical, administrative and so on) whose functions are for the most part regulatory' (Foucault 1991:144). The rape complainant, who is usually unmarried, a single mother, separated or divorced, can be seen as occupying space beyond the deployment of alliance and therefore in particular need of regulation and control. This analysis of the depiction of the woman's body in rape trials and its use as evidence of her credibility reflects such mechanisms of power and control operating within the legal discourses. 

This article draws on research conducted for a Channel 4 Dispatches documentary, Getting away with Rape which involved the monitoring of all contested rape trials over a four month period at the London Central Criminal Court, the Old Bailey in the Summer of 1993. Researchers sat in on trials and took transcripts of 30 trials and some official transcripts were also obtained. The research indicated that many rapists to go free, endangering other women and giving men a licence to rape again. This picture is confirmed by the official Home Office statistics which indicate that only a small proportion of reported rapes result in a conviction. Although the number of reported rapes has more than doubled between 1985 and 1993 the conviction rate for cases reported to the police according to Home Office figures has decreased from 24 per cent in 1985 to only 8.6 per cent in 1994 ( Home Office Statistics 1993). In this chapter I show how the use of evidence regarding the complainant's bodily processes and the reliance on medical opinion, are tools used by the defence to cast doubt on the woman's evidence and is an important factor in undermining her credibility. 

Court procedures imbalance the trial in favour of the defendant making it very difficult for jurors to convict. Juries are directed that in rape trials, it is a question of judging one person's word against another. Yet they are instructed to judge the credibility of the defendant and complainant according to totally different criteria. In the defendant's case what is considered relevant it is his reputation based on his lack of previous convictions and his occupation. In the woman's case it is her character and past sexual history. 

Various manifestations of misogyny have centred on the female body, all of which can be seen as forms of control over women's autonomy - from foot binding, circumcision, corsetry, to the more modern less overtly misogynist practices of plastic surgery, constrictive fashions (wearing of high heels and tight skirts) and dieting. In consumption-driven capitalistic societies, anxieties about controlling desires become displaced onto anxieties about the body which are frequently focused around eating disorders and sexuality ( Vines: 1993 :11). Rape trials where the woman's body, its secretions and its desires is the subject is close examination, function as a form of control over female sexuality. By focusing on the woman's body, rather than on her testimony, the impression is given that she ruled by her body and therefore her 'consent' or 'rationality', the core issue of dispute in rape trials, is implicitly questioned. Women are blamed for not taking sufficient precautions to protect themselves from male violence or for actively provoking violence by wearing short skirts or low tops, fashions which are actively promoted by the fashion industry, and if not adopted by young women, ironically render them unattractive, 'dogs', or lesbians. 

It is recognised that women's reproduction is subject to legal control. The law's involvement in the regulation of desire is less well appreciated. Male and female desire has to this day been conceptualised very differently. Male desire is regarded as more natural, more aggressive and more straightforward than female desire. In the nineteenth century, on the other hand, female desire was openly described as more dangerous and in need of legal control. The fear of the insatiable female is overtly expressed in the term 'nymphomania' resonating with the insatiable sexuality of women, devouring, depraved, diseased', conjuring up 'an aggressively sexual female who both terrifies and titillates men' (See Groneman, 1994: 337). The laws on divorce and on the control of prostitution exemplify how the legal controls operated in a discriminatory way in the nineteenth century. The Divorce Act of 1857 stated that a husband could divorce his wife for a single act of adultery whereas a woman has to prove adultery plus bigamy, cruelty, desertion, incest, rape or unnatural offences to obtain a decree. The Royal Commission on the Contagious Diseases Acts argued that there is 'no comparison to be made between prostitutes and the men who consort with them'. In the one case, the offence is committed as a matter of gain, in the other it is an irregular indulgence of a natural impulse. Walkowitz (1980) in her study of Victorian prostitution illustrated how working class women's bodies came to be seen as the sites of dangerous sexuality and as carriers of disease in need of draconian methods of regulation. The Contagious Diseases Acts of the 1890s gave police powers to restrain girls considered to be prostitutes and to force them to undergo compulsory medical examinations, while leaving their clients free to re infect them immediately afterwards. 

The portrayal of the female body in rape trials reflects such contradictions. The woman's body is seen as dangerous, seductive and unpredictable and, therefore, in need of control. Defence counsels and judges insinuate that women are neither honest nor aware of their desires, implying that they are ruled by their bodily urges. Judge Dean, in his summing up of a case in 1990 which he said lacked independent corroboration, told the Court: 'As gentlemen of the jury will understand, when a woman says 'No' she doesn't always mean 'No''. When criticised later he replied: 'In saying that I was simply repeating something I have heard over the last forty years. If that remark, as it seems to have done, has upset certain people, I regret it. I did not wish or intend to upset anybody' (Guardian April 12, 1990). 

He is voicing a common view which is used to support the argument that the women do not share male rationality, in other words their evidence is no evidence at all. If women do not know whether or not they want sex, then rape cannot happen as their will is always confused. It is argued then that women regret their lust and are thus prone to make false allegations, to pretend that they did not consent at the time. This makes them irrational and untrustworthy. If women do not know their own minds the whole concept of consent becomes irrelevant and the very definition of rape as sexual intercourse without consent is undermined. To return to Judge Dean he added that he might repeat the remark if he was trying a case where there was no support of any allegation of rape. Audrey Wise, Labour MP said the judge's comment was appalling. 'It is an invitation to rape and it makes men feel it is okay. I do not think this man should be a judge'.

'They say No but mean yes', refers both to the woman's hesitation at appearing to be sexually desiring to protect their reputation, and to the myth that women do not really know what they desire, as they are irrational beings. There are various ideas confused here. Clearly, in the nineteenth century, many women feigned resistance when they really desired sex, but women's pleasure in sexuality is so taken for granted to-day that there is no reason why such feigning should still take place. There is a world of difference between feigning and refusing. 

The argument that 'women mean yes when they say no' has dangerous implications. If the female body has an existence of its own, totally out of control of its occupant, evidence of lack of consent is rendered irrelevant. Implicit in these ideas is that not only does a woman not know her own desires, but that she is responsible for the 'uncontrollability' of male desire once it is aroused. The defence counsel then puts arguments forward such as 'Did she lead him on, prostitute herself, or consent and then change her mind at the last minute when the man was unable to control himself?' The idea that male sexuality once aroused is uncontrollable firmly shifts the blame onto the woman. Despite her own irrationality and lack of control, she is expected to exercise control on behalf of both of them. 

Evidence in British trials is presented to imply that the woman enjoyed the experience against her better nature or in order to support the man's argument that she consented. In other words 'she said no but meant 'yes': Witness this exchange which comes from one of the trials Zsuzsanna Adler (1987: 10) covered in her research:

Prosecution Counsel (PC) And you say she consented
Defendant (D) I didn't say she consented
PC: Did she agree
D: She didn't agree
PC: Having said no at first she just gave in?
D: She enjoyed it
The judge intervened 'The enjoyment wiped out her initial resistance - is that what you are saying?'
D: Yes

This discussion is important as it depicts one of the major underpinnings of rape trials. The conception of what comprises sex is based on an archetypal male model where a male predator overcomes the resistance of a passive female whose resistance is against her better interests. Penetration of the penis is what is presumed to give pleasure to women regardless of any foreplay or other sexual activity and assumed evidence of 'enjoyment' represents consent. 

The assumption here is that a woman could want sex without even knowing herself. It reduces the whole issue of consent to absurdity, in which the woman is denied any subjectivity or knowledge of her own desire. This becomes clear in the cross examination of the defendant: 

Prosecuting Counsel: You gave her a kiss but there was no response.
Defendant: No
PC: That is because you frightened her into submitting?
D: No... Women, they're really complicated you know. I've come across women who play hard to get, but when I make a move they respond.. I'm saying she wanted it. Her body wanted it but her mind was somewhere else.
PC: You told us she wasn't a good conversationalist?

The response of the prosecuting counsel is as baffling as the defendant's statement. He does nothing to counter the defendant's assertion that the woman really wanted sex by referring to her own account of the assault, in which she described how she had tried everything to get him to go, making it quite clear that she never wanted to have sex with him. He does not suggest to the jury that the defendant's sexist views corroborate her version of events, as he does not believe that when women say 'no', they mean 'no' and that by arguing that she was lubricated, he is asserting his right to take the decision for her. Her subjectivity is irrelevant. This could be seen as an example of a discourse reflecting 'the hysterization of women's bodies described as 'which he argued was one of the mechanisms of knowledge and power centring on sex' (See Foucault 1990:104).

Arguments about whether or not women were 'lubricated' are particularly pernicious. A woman police officer I spoke to, who had been on the special course on sexual assault at Hendon Police Training college in London, told me quite fallaciously that forensic tests could ascertain from the fluids whether or not the complainant had consented. If some police believe this, jurors are often equally confused by the lack of injuries. It is understandable that such an argument can plant a seed of doubt in the jury's mind, particularly if not refuted by the judge.

Part of the difficulty lies in the judicial view of the relation between sex and violence. Forcible persuasion where a degree of violence occurs is axiomatic. Violence during a sexual encounter is somehow neutralised; Violence is a legitimate part of the 'courting' process. Even where the complainant gives evidence of violent assault or threat, this does not necessarily preclude her consent. The defence will argue that only extensive injury or evidence of her active resistance, provides adequate proof of her non consent. The woman is a sexual being, her rationality is therefore always debatable and her claim of rape always suspect. Men know best what her body really wants, and she is not more than her body. This is what renders women fickle and untrustworthy. 

The trial focuses on what men define as sexuality, not on women's experience of sex or rape. Men are presented as having a biological need for sex. Sexual appetite, it is argued, is synonymous with hunger. If, therefore the man is deprived of sex, a sexual assault is understandable, even pardonable. The man's alleged sexual frustration is then presented as an excuse for the offence and legitimates a low sentence. An example of this is where Sir Harold Cassel, aged 72 (Kennedy 1992: 111) freed a child molester, saying his pregnant wife's lack of sexual appetite had caused three sexual assaults on his 12 year old stepdaughter. He argued 'pregnancy led to a lack of sexual appetite in the lady and considerable problems for a healthy young husband'. He went on to accuse the woman of 'encouraging' the assaults. The mother described how her daughter's life had been ruined and went on to say 'As far as the sexual side, my husband did not go without the whole time through my pregnancy, so I do not know where the judge got his information from'. 

In rape trials as in pornography, the female body is publicly portrayed and debated. It is her body, not his, that is put on trial. Her body's secretions and underclothing are scrutinised, her photographed injuries distributed as exhibits, her body's level of sexual arousal debated without regard to her testimony. She is objectified in similar fashion to her objectification in rape itself. This is the meaning of the term 'judicial rape'. The analogy with porn is relevant here: 

'Porn puts into circulation images of sexuality that have definite meanings connected with them; sexual pleasure for men is initiation and dominance, and for women submission to men's depersonalised needs. The problem is that these meanings feed general definitions of sexual identity and sexual activity' (Coward 1984: 176).

Catherine MacKinnon (1987) drew attention to the rape trial as a pornographic spectacle as by being forced to speak about sex, the woman herself becomes a pornographic vignette. The complainant must describe in intimate detail every part of her body that was assaulted in words which would embarrass women to refer to at all, let alone in such a public setting out loud.Questioning women about male penetration can be seen as giving pleasure synonymous to a pornographic vignette.

Judges frequently direct complainants to 'speak up' in the lofty setting of most Victorian court chambers. For a woman, unused to speaking in public it can be shattering. The paradox is that the very use of such language, referring to private sexual parts of the anatomy, is sufficient to render a woman 'unrespectable'. Many women never say such words even in the privacy of their homes, let alone to strangers in open court. Except in pornography the kind of details described in rape cases would never be articulated. It is for this reason perhaps that so many women find being cross examined such a nightmare. Smart (1990: 205) aptly comments 'She is required to speak sex, and figuratively to re-enact sex : her body and its responses become the stuff of evidence. The act of describing in exact detail what the man did and how she responded is enough subtly to render her 'unrespectable' . 

Various themes relating to the female body emerge with regularity in rape trials. The frequent portrayal of the female body as bloody or slightly disgusting is combined with its portrayal as dangerous, enticing and brimming with uncontrolled sexuality, incitement to male lust, implicitly a danger to the moral order. Comments made by defence counsels in cross examination are often fused with desire and repugnance, disgust and fascination. In one trial the defence counsel asked 'And that he (the defendant) was able to insert his penis easily because you were turned on in the normal fashion - nothing to do with periods or anything else; that is right, isn't it'? Alison Young's (1990) analysisof the representation of women's bodies in Greenham women's anti-nuclear protest is relevant here. She argued that women were subjected to defilement through the language and images of revulsion and disgust which equated them with excrement, dirt, blood and disease: 'The Greenham women have been so policed in the general literal sense through the increased deployment of personnel at the base and in a less usual sense through the repeated accounts in the press of their dirtiness, their insanitary habits, their morally defective values' (Young 1990 : 62.). 

She points out that both their bodies and their moral selves were attacked. The emphasis on menstruation and handing round used panties in rape trials can be understood as a similar process of defilement. The Greenham women were transgressing lines of gender, territoriality, sexuality and familiarity and had to be policed in the same way that the suffragettes were policed through force feeding. 

Menstruation

When attending rape trials I was puzzled by the frequent reference to menstruation. I began to understand it as carrying a dual purpose: to publicly humiliate the complainant (as no respectable woman would broach such a subject in public, let alone in the lofty setting of a Crown Court) and to imply that she was a bit off key, perhaps totally irrational, certainly an unreliable witness, prone to make false allegations. The frequent reference to menstruation in rape trials also alludes to women as seducers whose powers are overwhelming when menstruating. 

The menstrual taboo, as Jane Ussher (1991) points out can be traced back as far as recorded time. In many societies women are seen as polluting either in general or at particular times. A strong taboo against intercourse with a menstruating woman has existed since antiquity. The Old Testament states that god defines a menstruating woman as unclean for seven days, and anyone who touches her or anything she has touched or anything touched by someone she has touched is also unclean. Both Jews and pagans saw menstrual blood as poisonous, and responsible for child deformities (Ranke-Heinemann 1991:21). In some communities women have been confined to menstrual huts and menstruating women have been seen as contaminated and banned from the worship of God. They are defiled. In the nineteenth century disordered menstruation, gynaecologists argued, could lead to injury to the nervous system and thus to mental illness. (Groneman 1994 : 337)

The menstrual taboo is evident in rape trials. The defence counsel's disgust is often expressed quite blatantly. Witness this excerpt from the cross examination in a trial heard in August 1993. Even the judge intervenes in this exchange between the defence counsel (DC) and the complainant (C) to question its relevance. 

DC: Let me put it to you that in fact you were just coming off, finishing your period at the time of having sexual intercourse with Mr Jones. Do you agree with that?
C: I was on for another couple of days
DC: Another what?
C: Two days. I was on for another two days after that.
DC: This is the early hours of Wednesday, so do you mean until the Friday, or when?
C: I can't remember. What has my period got to do with that?
DC: Just answer the questions please
C: I don't know.
DC: You see, let me tell you what I'm driving at. I am putting it to you that you were a willing partner in having sex with Jones.
C: No, I wasn't. It's not right. I wouldn't go near him with a bargepole. 
DC: These questions may not be very tasteful, but I have got to put them to you. In order for him to insert his penis, he has to cope then with the debris of your period and the tampon, is that right?
Judge: Well, she can't answer what he would or wouldn't find easy.
DC: The point is - I am sorry to have to put it to you - that the channel was obstructed.
Judge: I think you're making a comment
DC: Am I? All right. 

This farcical cross examination belies belief. How is it possible that a complainant is asked whether her tampon and the 'debris' of her period caused the rapist problems? What on earth is the justification for barristers indulging in such questioning? 

There are links between the medical preoccupation with women's menstruation and contemporary social and cultural concerns. Shuttleworth (1990) draws an analogy between the obstruction and accumulated waste that dominated Victorian theories of female economy with the laissez-faire economics elaborated by economists. Like the body, the economy could only thrive with the free flow and circulation of commodities, unimpeded by blockage or government interference. Female thought and passion, like government interference, were seen as throwing the whole organism into a state of disease.

Forensic and Medical Evidence 

If a woman physically resists and is severely hurt, she is told she should have acted more passively, on the other hand, if she decides not to resist she is seen as accepting the violence, clearly this is a no win situation (Kelly 1988 p184)

Medicine and psychiatry are power-knowledges that are also called on to contribute to discrediting the complainant. As Foucault pointed out (1990 p 45) 'medical and psychiatric investigations, often had the apparent objective of saying no to all wayward or unproductive sexualities'. In this way medical and psychiatric knowledge and practice are part of the means by which gender divisions in society are maintained (Doyal 1983 :379). How the reports are obtained is important since the prosecution ( representing the complainant) can only call for two psychiatric or medical reports but the defence, on the other hand, can shop around for doctors who are prepared to write medical reports which is sympathetic to the defendant's case - and presumably receive a hefty fee for doing so. It appears that forensic and medical evidence is a crucial area of dispute between the prosecution and defence lawyers where conflicting medical opinion is often used to plant seeds of doubt in the jurors minds about whether or not the woman consented. Such evidence is based far more on bias and prejudice, and no reference is ever made to research findings on, for example, the reactions of rape victims or the tactics commonly used by rapists.

Medicine is deeply involved in the reproduction of a specific view of the intrinsic character of women and of sexuality. For this reason even when the complainant has extensive injuries she will not necessarily be believed on the grounds either that 'she liked a bit of rough' or that the injuries could be self inflicted. In one of the few cases (heard in 1993) involving a couple who had been previously married, but had separated as a result of the husband's violence, a wife who had been hounded by her husband and had two injunctions out against him, failed to convince the jury that she had been raped in spite of her appalling injuries. Her nose had been broken and according to medical evidence she had strangulation marks around her throat. She had reported the rape and assault immediately and been examined by a doctor within hours. In court she was faced with a barrage of such questions as 'Did you rub his penis through his jeans?' and statements such as 'You helped him put his penis into your vagina and had consensual sexual intercourse.' 'You weren't frightened'. 'He never put his arm round your throat' Her denials went unheeded even when she insisted it was the first day of her period and she would never have had sex during this time. The defence counsel argued that the defendant did not know she had a period, to which she replied' He took the tampon out so he should have known'.' It was love making. You told him you loved him and you were glad he was back.'. The defendant was acquitted of rape but was found guilty of gross bodily harm which is are far less serious offence. 

Absence of injuries is taken as evidence of consent rather than due to a paralysing fear that she might be killed, which leads to a decision that the best chance of survival is to submit. Sharon was asked why she did not dig her fingernails into her assailant's penis, or 'put a construction in front of the door' when her assailant went to the toilet. Both of these actions are ludicrous for a woman who is in fear of her life to contemplate.Women certainly have reason to believe the threats and to fear for their lives. The defendant usually knows their name and sometimes where they live or work. In one case where the defendant had broken into a woman's flat, raped and threatened her, he returned some months later to rape her again. The gravity of the threats is grounded in real experience. In two cases I encountered, the rapists had returned to rape the woman again. In court however these threats are trivialised. Complainants are cross examined in detail about whether they enjoyed the sexual attack, whether they were drunk at the time and consented to sex but regretted it later and made false allegations, whether they were having another relationship on the side and had to cover up their infidelity to a boyfriend with a false story and so on. One of the difficulties is that women subjected to threats often do not suffer visible injuries or the injuries consist of slight bruising. 

Many defendants argue that because the woman did not resist, they did not know that she did not consent. Some rapists, according to Wyre & Swift (1990: 6) who set up a treatment programme for convicted rapists at the Gracewell clinic in Birmingham argue that they kid themselves that it was not rape and say 'Why didn't she stop me?... she must have known I didn't want to do it' as if it was her responsibility to save him from himself. Among rapists Scully (1990) interviewed, 69 per cent agreed with the idea that most men accused of rape were really innocent and 65 per cent believed women cause their own rapes by the way they act or clothes they wear.

Doctors play a crucial 'expert' role in analysing women's responses and sometimes give conflicting and distorting accounts of the 'typical' bodily signs and symptoms of rape. A common argument is that if really raped, the complainant should have had vaginal injuries. This does not fit with the evidence from the medical examination of rape victims where vaginal injuries are rare for the simple reason that most women are too terrified to resist. Yet again and again, doctors called by the defence argue that women who have been raped should have vaginal injuries. The prosecution are inept at countering such claims and fail to draw on the common response of both men and women to attack when threatened with violence or with their lives. Men who are raped or assaulted behave in exactly the same way. There is a strong argument that 'expert witnesses should be called to explain to the jury just what is known about rape and victim's reactions. Since many women who are raped are in a state of panic due to threats that usually accompany rape and in reality are often being threatened with death, at some point they may decide they have a better chance of survival if they submit, but that this in no way indicates consent. 

This tactic was used by the defence to great effect in the case heard in 1993 in which conflicting medical evidence was fatal to the complainant's case. The police doctor in giving evidence quite correctly argued that evidence shows that 50 per cent of rape victims show no injury to their genital area. Also some skins bruise easily, and some are more resilient. He also argued quite correctly that black skin does not show bruising as quickly or as easily as fair skin. He then described how he had spent two hours with the complainant and found she was literally frozen with fright. Her pulse and blood pressure were both 'so high that if the pulse rate went higher there would be some sort of heart failure'. He described how she was in great pain and having vaginal spasms which made it hard for him to examine her. 

The defence doctor refuted these arguments by saying that you might expect a victim of sexual assault to have bruising or redness and abrasions, especially if the victim was a virgin. She suggested that the increase in the level of blood pressure and pulse rate could have been due to many other causes such as smoking cannabis, (the complainant admitted to having two puffs of a spliff), drinking ( she had had one drink), running or consensual sexual intercourse. She argued that the very high blood pressure must have been 'pathological' and that the forensic doctor's examination had been inadequate. In further cross examination by the prosecution counsel, the defence doctor did admit that she was not suggesting that pulse rate and blood pressure could be faked but that if she had been in any stressful situation her pulse and blood pressure could have been kept up. 

The judge in his summing up dismissed the medical evidence as not amounting to corroboration. He pointed out that the defence doctor had had a great deal of experience of examining rape victims but did not point out the omission in her confident statement about how virgins would be more likely to be bruised : that the main reason why women do not show signs of intercourse whether they are virgins or not. is that women who are too terrified to resist obviously show no physical signs of struggle or resistance. The judge repeated the defence counsel's argument that the pulse rate could just as easily be high as a result the doctor's hands touching her legs as it could of rape. In one case, several police officers, including a police surgeon, gave evidence that the woman was shaking with fear and distress, tears were streaming down her face, she wanted to wash herself frequently and was afraid afterwards to go out alone. They all agreed she was in acute distress and showing every sign that she was suffering from what has been identified as the rape trauma syndrome. Yet the prosecution counsel failed even to mention her distress in his summing up. In this case I abandoned my role as participant observer and followed him out of the court and asked him why he had not mentioned her distress. He responded that it was absurd to regard the woman's state as corroborative and dismissed the judge's view as irrelevant. This exemplifies the lack of sympathy between the prosecution counsel and the complainant and the way it can prejudice her case. Forensic evidence is relevant only in establishing that intercourse took place, not whether it took place with or without consent. There is often disagreement over what constitutes corroboration. In the UK the woman's distress is not regarded as corroborative, but in Scotland it is (See Brown et al 1992). 

The justification of excluding the effects of rape on the complainant is in my view extremely weak. Judge Smedley on 1 September 1993 in a case heard at the Old Bailey comments on why evidence of the complainant's distress should not be regarded as relevant at all: 'A word of warning. If the account the complainant is giving was completely fabricated you may think she is clever, then clever enough to act out distress'. Women's distress is excluded mainly on the grounds that she is the source of the distress and corroboration has to be evidence from a different source. Yet, as we have seen, judges do not agree as to its relevance which is one reason why training judges is so necessary.

One of the main findings of research into the reactions to rape (Holmstrom & Burgess 1978, Roberts 1989, Foley in Lupton C & Gillespie, T 1994:44) is that although there are common patterns, there is no typical reaction. Some women express anxiety immediately, for others the reaction may be delayed, but every bit as traumatic. Nor do men all react to traumas in a similar fashion, but this is not held against them in the same way. However, a common tactic used by the defence to support the idea that the woman is making a false allegation is to suggest that her reactions are not typical of a rape victim. In one of the trials I monitored in 1993, evidence that the complainant had not broken down was used to imply that she had not been raped. In her cross examination the defence counsel argued that according to the doctor the complainant was 'not at all distressed'. She cried for about twenty seconds while talking, but then smiled and carried on talking? Here is her cross examination by the defence counsel: 

Defence Counsel:  What signs, in the light of his Honour's questions, were you showing of distress to this doctor?
Complainant: Well, I did cry and ...
DC: Anything else? I mean, is this doctor right or wrong or just mistaken?
C: Well maybe, I wasn't showing signs of distress at some times, but I was feeling it.
DC: I see. So this doctor - it was a woman doctor failed to see that underneath it you were, in fact, distressed and, as you said, you were not at all distressed, making the point you cried for about 20 seconds but then smiled and carried on talking. What is the picture that we should have?
C: I was distressed, but she was doing her best to try and, you know, be nice and cheer me up

The complainant little realises that the doctor's evidence is used by the defence counsel to imply that since she was not distressed during the examination, she could not have been raped. What is apparent here is the way the complainant's description of her state of mind is disregarded and the doctor's view prevails.

The effect of drugs and alcohol on 'spoiling' reputation

Of all the factors used to discredit the complainant, the most common was the consumption of alcohol and drugs. Yet the defendant even if blind drunk, was rarely questioned about his use of alcohol. In one trial, on the other hand, it was alleged the complainant was drunk even though she was completely tee total. The use of alcohol and drugs has quite different meanings for men and women. For men heavy drinking serves to enhance their male status, it signifies 'real manhood'. For women on the other hand alcohol carries the taint of immorality and promiscuity. Elizabeth Ettorre, (1992:38) a British sociologist who studied attitudes to women and alcohol, suggests that 'a woman who drinks does not need to be a prostitute to have a promiscuous image. She is promiscuous by the very fact that she is a drinker'. 

Drinking and drug use was used to discredit the complainant in two ways. The first was to suggest that their consumption would lower the woman's inhibitions and thus she would have been likely to consent to something which she would regret later. The second was to suggest that a woman under the influence of alcohol would be more likely to act irrationally or vindictively and make a false complaint. Drink and drugs are seen as particularly dangerous in unleashing a woman's sexuality, which once unleashed is irresistible to men. A man is not held responsible for his sexual desires; all the onus is on the woman to control his sexuality. According to Stanley Brandes's (1981) study of sexual relations in an Andalusian town, women are portrayed as dangerous and potent while men are seen as suffering the consequences of female whims and passions. Women are viewed as seductresses and whores possessed of insatiable lustful appetites. When women wielded their power, men cannot resist temptation and are forced to relinquish control over their passions. 

Doctors frequently disagree about the effects of alcohol. In one trial I attended, when asked what the effect of drinking the equivalent of four to five pints would be and the likelihood of it 'reducing inhibition', the woman doctor of 36 years experience replied ' In some people it can. It depends on the person. Some people can become quite stubborn or stroppy'. The defence can call their own doctor to refute the evidence of the prosecution's doctor. The defence doctor will then reiterate that it lowers inhibitions. 

Evidence that the complainant has taken drugs, even in the past, is fatal to obtaining a conviction. Notions of 'purity' and 'pollution' are intrinsic to sexuality and drug abuse. Mary Douglas (1966:113) a British anthropologist, defines pollution as 'a type of danger which is unlikely to occur except where the lines of structure, cosmic or social, are clearly defined' . With women the social boundaries are more clearly defined in the sense that there are clear lines between what is and is not legitimate or respectable behaviour for women compared to men. The controls over their social behaviour are more stringent. Transgressing such boundaries (poisoning themselves, being out of control and so on) turns female heroin users into polluted women: As Ettotte (1992: 76) argues 'as a polluted woman with a spoiled identity the woman heroin user is low on the hierarchy of women generally and women substance users in particular. Being viewed as 'deviant' and a 'whore' she is engaged in using a drug which is seen as low (bad, evil) on the hierarchy of drugs. The lower the drug the closer the connection to the whore image'. 

In a case involving two compalinants who had a drug history but according to medical evidence had not touched drugs for over 2 years, the defence counsel, drawing on the stereotype of the female heroin addict, summed up with sickening irony:

It's easy to feel enormous sympathy for the two complainants because of the wretched way they live their lives. One might just find oneself going sympathetically along with what they say but be careful. You're not dealing with a typical witness. You must not look at every witness in the same way. But of course you are considering the credibility of their evidence.

It's impossible for a heroin addict to get off the drug. If it is possible for someone to be weaned off it takes a very long time. Money is the one thing that people in her situation want. Drug addicts will fail to behave in a way normal people would. 

The conclusion is clear. She must be supporting her alleged habit by prostitution. He ignores the doctor's evidence that the complainant was clean and not under the influence of drugs or drink but plays on the prejudices of the jurors. He then alleges the complainant is a spiteful person and is 'the sort of person who with five pints of Tennants in her might go to a police station and make up a story'. 

Being under medication is sometimes used as an argument that the woman consented. On one occasion the complainant's medication on release from mental hospital was held against her. This was used to suggest that she had sex willingly with a complete stranger in a lift shaft of the underground in the middle of the night and then made a false allegation. In this case the defendant was also HIV positive and to add insult to injury the complainant had not been informed. the defendant was set free after a retrial where the jury was again unable to reach a verdict. 

Conclusion

Insufficient attention has been paid to the function of the trial process in policing women's sexuality. Several studies have recently examined how power and discipline produces 'docile bodies', in particular, Foucault pointed to the emergence of a new disciplinary power in the modern era directed against the body. Forms of violence against women, from rape and domestic violence to sexual harassment and sexual abuse are perhaps the most oppressive by-products of Foucault's 'technologies of sex'. The disciplinary techniques, such as power reflected in the use of abuse, both verbal (such as slag and slut) and physical, have a direct effect on regulating how women and girls behave, how she feels about her body, her desires and her self confidence and how constricted her life can become. Through court procedures, women who do not behave in a stereotypical 'feminine' way, or women who speak out about male violence, render themselves open to such disciplinary techniques which are laid bare in the court drama. 

According to Adrian Howe, an Australian criminologist  (1994: 201) the reason why women so rarely commit criminal offences may well be due to the greater powers of surveillance and discipline they are subjected to both in childhood, adolescence and adulthood. She calls on the reconceptualising of penality to include a wider range of sanctions and controls and 'refuse the discursive boundaries which separate policing from punishment'. The women who are brave enough to speak out about such disciplinary powers should not be named 'victims' or even survivors but rather rebels who are unprepared to remain silent. By reporting assaults to the police, they become targets of disciplinary punishment themselves for such transgression. bel hooks, an American feminist makes a similar point when she argues ' Within patriarchal society, women who are victimized by male violence have had to pay a price for breaking the silence and naming the problem. They have had to be seen as fallen women, who have failed in their 'feminine' role to sensitise and civilise the beast in man (hooks 1989: 89). This is one of the pernicious aspects of Katie Roiphe's (1993) book 'The Morning After'. is that she is joining in the ostracising of the victims of rape by arguing that they have a 'victim mentality'.

Foucault (1980: 96-7) called for an examination of how power and discipline produces docile bodies 'at the extreme point of their exercise, and to explore punishment and the power to punish at the local level, especially how they are embodied in 'local, regional, material institutions'. The cross examination of rape complainants is an example of just such a practice. The latent purpose of trials can be seen to strengthen the control and disciplinary practices over young women who are considered to be 'leading men on', acting independently by being single parents or complaining of enforced sex, part of the normal oppressive system of subordinated sexual relations. The trial subtly turns what is purported to be a judicial examination into a condemnation of the complainant, her punishment. Press reports often then add to this character assassination as shown in the Guardian report of October 26, 1993 of the Kydd case where 'Man Was Acquitted Of Raping 'Slut Of The Year' was the heading to the report of the trial.

The task of the jury in rape trials is to weigh up 'one person's word against another' in order to decide whether the prosecution has proved that the defendant is guilty 'beyond any reasonable doubt'. By constantly questioning women about their most intimate bodily processes regarding, for example, lubrication and menstruation, their 'moral' character' is undermined. The association with 'women' and 'the body' is aimed at dissociating women from the faculty of 'reason'. The implication that women's bodies are 'out of control', particularly when under the influence of drugs or alcohol, leads to the assumption that a women's rationality is in doubt, and her word cannot be relied on. The man's body is rarely a matter of debate even when under the influence of far greater quantities of drugs. His rationality and credibility are taken for granted. It is time this double standard was challenged. 

Rape trials can be seen as a spectacle of torture, by which rather than protecting women, the trial can be seen as a public mechanism for the control of female sexuality. The defilement of the complainant through language puts her publicly on trial. The purpose of the cross examination of the complainant appears to be to uncover the 'real' culprit of the trial, the whore, the insatiable female harridan, vengeful and often in disguise: Behind the young beautiful girl lurks the archetypal Eve who ensnares male rationality and drags men down. Such myths protect men from allegations and thereby from responsibility for their own violence. It is a consolidation of heterosexual privilege; the privilege of men to decide when a woman says 'yes'; the right of men to have sex when, how and when they want; the right of men to oppress women.