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An adult woman exposing her navel was also considered indecent in the West into the s and s, and even as late as the s. It has been noted that a term such as "exposing one's person" relates back to the United Kingdom Vagrancy Act and Evans v Ewels [64] where it was said that the word "person" was a genteel synonym for "penis" or "vulva". In the past public nudity in England and Wales could also be punished as "disorderly behaviour" under the Public Order Act , sections 4A and 5. She was acquitted in by the Ontario Court of Appeal on the basis that the act of being topless is not in itself a sexual act or indecent. However, it has been held that the word "person" in s5 of the NSW Summary Offences Act is not limited to "penis" or "vulva". Legislation ranges from simply exempting breastfeeding from laws regarding indecent exposure, to outright full protection of the right to nurse. Cornell University Law School. The defence appealed on the point of the validity of the charge of outraging public decency, which was dismissed by the Court of Appeal , which upheld the trial judge's ruling and went some way to restating the law in this area. The laws of New South Wales, the Australian Capital Territory and the Northern Territory use the term "person", while in the other States the exposure refers to the genital area.

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