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When audacity of immorality is at issue, the celebrated case of Smith v Hughes is always referenced. It is also used to explain the mischief rule in law. By the 19th century, the English society had become so notorious for the infiltration and embarrassment caused it by commercial s3x workers on the streets of London. Prostitution had become a profession of its own and takes a prime place of consideration. In 1791, a police magistrate was said to have estimated the number of prostitutes in London alone as 50,000. They had become such an embarrassment that a surgeon, Lord Acton, said he counted 185 of them on his way home one night. Thus, to curtail this embarrassment, the 1959 Act was promulgated by the English law to tackle the menace. Section 1(1) of the Act prohibited a prostitute from offering her services “in a street or public place.”
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