title: The Night of the Hunter (film)

text: Following his release, Powell makes his way to Harper's tiny hometown, where he charms the townsfolk and woos Harper's widow, Willa, a waitress for Walter Spoon and his wife Icey. Overnight Powell manages to win the town's trust and weds Willa; only John remains instinctively distrustful. Powell suspects that John knows where the money is hidden and in a cornering John accidentally reveals that he indeed does. Later as Powell begins to question Pearl, John reminds her of the promise whereby he inadvertently gives away that Pearl knows the secret too. Willa becomes deluded that Powell married her to redeem her soul, and begins preaching alongside him in tent revivals. However, she later overhears Powell threatening Pearl to reveal the money’s whereabouts whereupon she's disabused of her faith in Powell.


title: The Night of the Hunter (film)

text: Powell murders Willa the same night, dumping her body in the river while spreading the tale that she left her family for a life of sin. Powell proceeds to threaten the children before learning the money is hidden inside Pearl's doll. While fishing, Birdie Steptoe, an elderly friend of the family, discovers Willa’s body, but refrains from telling the police in fear that he will be accused of the murder.


title: The Night of the Hunter (film)

text: The children escape an enraged Powell and attempt to seek refuge with Birdie, who has drunk himself into a stupor. They use their father's small johnboat to flee down the river, and eventually find sanctuary with Rachel Cooper, a tough old woman who looks after stray children.


title: The Night of the Hunter (film)

text: Powell tracks them down, but Rachel sees through his deceptions and runs him off her property with a shotgun. Powell vows to come back after dark, and does. During the all-night standoff, Rachel gives Powell a face full of birdshot, who flees into her barn. She summons the state police, who arrive and arrest Powell for Willa’s murder. John breaks down during Powell’s handcuffing, having a flashback of his father’s fate. He beats the doll against the struggling man in anguish, spilling the cash out.


title: The Night of the Hunter (film)

text: During Powell’s trial John once again transposes Powell for his father and cannot bring himself to testify against him. Following Powell's sentencing, Rachel takes John and the other children away as a deranged Icey leads a lynch mob toward the police station. Powell is escorted out the back to safety just in time, but the prison hangman promises to see him again soon. John and Pearl then have their first Christmas together with Rachel and their new family.


title: The Night of the Hunter (film)

text: This was the only film directed by the actor Charles Laughton. Laughton had directed plays on Broadway, most produced by his friend Paul Gregory.


title: The Night of the Hunter (film)

text: Harold Matson, a literary agent, sent a copy of the 1953 novel "The Night of the Hunter" by Davis Grubb to Paul Gregory. He sent the book to Laughton, who loved it and described it as a "nightmarish Mother Goose story". Laughton contacted Grubb, and the two of them instantly got along very well. He traveled to Philadelphia, where Grubb lived, and they spent five days discussing ideas for the film. Grubb had studied art in college, so he offered to draw sketches as a form of inspiration. Laughton loved the drawings, and many of them were used in the film's storyboard.


title: The Night of the Hunter (film)

text: At first Grubb was being considered to write the screenplay himself, but the studio wanted to hire someone with experience writing for films. James Agee was hired as the screenwriter because he was from the South and had experience writing about the Depression. Agee began writing in April 1954, and finished in June, but his script was 293 pages: much too long for a feature film. Laughton made significant rewrites to the script, and his was the version used for shooting, even though he insisted that Agee be credited as the only writer. Agee's original script ended with a shot of children's faces floating among the stars, an idea that was eventually moved to the opening of the film. Throughout 1954, Gregory worked with the Production Code Administration to change the script to meet the guidelines of the Production Code. There was much concern about depicting a preacher on screen as an evil person, and Gregory made an effort to make the character of the Reverend not appear to be a real, ordained minister. Eventually the script was approved, but Protestant groups who had read the script continued to object to the film's production.


title: The Night of the Hunter (film)

text: While preparing for the filming, Laughton studied silent films by viewing their original nitrate prints, including "The Birth of a Nation", "Intolerance", and "The Four Horsemen of the Apocalypse". He wanted to "restore the power of silent films to talkies."


title: The Night of the Hunter (film)

text: The budget of the film was a little under $600,000, of which about $75,000 was for the rights to adapt the novel.


title: The Night of the Hunter (film)

text: Laughton's initial thought after reading the novel was to cast himself in the role of the preacher, but Gregory convinced him that no studio would finance a film unless they cast someone else. For the most part, he did not hold traditional auditions for the actors; he simply met with them to get a sense of their personalities and whether they were right for the role.


title: The Night of the Hunter (film)

text: Laughton considered casting Gary Cooper as Harry Powell, but Cooper did not accept the role as he thought it might be detrimental to his career. John Carradine expressed interest in the role of the reverend, as did Laurence Olivier, but his schedule was not free for two years. Robert Mitchum was eager for the part of the preacher. When he auditioned, a moment that particularly impressed Charles Laughton was when Laughton described the character as "a diabolical shit," and Mitchum promptly answered "Present!" Laughton liked Mitchum for the role partly due to his sexual persona, but Grubb was concerned about the character of the preacher being considered sexual. Laughton told him, "If you want to sell God, you have to be sexy."


title: The Night of the Hunter (film)

text: Agnes Moorehead, Grace Kelly, and Betty Grable were all considered for the role of Willa Harper. In the end Laughton chose Shelley Winters because he felt she had a vulnerable quality and was more of a serious actor than a movie star; she committed to the role only two weeks before filming began. In her 1989 memoir, Winters described this as "probably the most thoughtful and reserved performance I ever gave".


title: The Night of the Hunter (film)

text: Laughton's first pick for the role of Rachel Cooper was his wife Elsa Lanchester. Jane Darwell and Louise Fazenda also were considered. Lanchester, for reasons unknown to Laughton, turned down the role, suggesting silent movie star Lillian Gish for the role. A doubtful Laughton went to New York for the purpose of watching films in which Gish starred. These included the shorts and feature films she made with pioneer D.W. Griffith. Gish had gotten word of his watching these old movies, and when she asked him why, he replied, "When I first went to the movies, they sat in their seats straight and leaned forward. Now they slump down, with their heads back, and eat candy and popcorn. I want them to sit up straight again."


title: The Night of the Hunter (film)

text: Principal photography of "The Night of the Hunter" began on August 15 and ended on October 7, 1954, a total of 36 days of shooting. Laughton kept the editor and musical composer on set during filming, which was very uncommon at the time. Mitchum originally suggested Laughton to shoot the film in authentic Appalachian locations, but the director could not afford the budget to do on-location shooting. Besides, he wanted to create the film's unique look on Hollywood sound stages and found what he was looking for at Pathé, Republic Studios, and the Rowland V. Lee ranch in the San Fernando Valley. Certain cutaway shots and compositing shots were shot in West Virginia. Laughton hired Terry Sanders as second unit director in order to scout and shoot the river scenes because he had recently directed an Academy Award-winning short film "A Time Out of War", which mostly took place on a river.


title: The Night of the Hunter (film)

text: Rather than shooting with traditional takes, Laughton had the crew only slate at the beginning of each reel of film and let the camera roll continuously until the reel ran out. This was so that he could direct the actors without waiting to reset the camera and sound equipment, not unlike the way silent films used to be directed. Shelley Winters told Laughton she had this image of Willa as being "a fly fascinated by a spider, and she very willingly walks into this web". He liked this image and told her to channel that into the performance. Mitchum's performance in the film has been described as Brechtian acting, which Laughton had extensive experience with. According to Lillian Gish, Laughton was very unsure of himself on set as this was his first time directing a film, and when someone would give him a suggestion he would start talking about fears that his whole vision was wrong. Laughton's directing style was supportive and respectful of the actors' input and several of the actors have said it was among their favorite professional experiences.


title: The Night of the Hunter (film)

text: The director of photography was Stanley Cortez, who also shot Orson Welles' 1942 film "The Magnificent Ambersons". Because Laughton had very little experience working with film, Cortez would visit his house to explain various concepts of camera lenses, camera heights, and what effect each of them gave. Laughton told Cortez that the nitrate prints of the silent movies that he had been watching for research impressed them with how sharp they looked, so he asked Cortez to create that same sharpness for "The Night of the Hunter". The studio brought most of the crew from a recent film "Black Tuesday" because they had worked so well together, and Cortez had experimented with a new black-and-white film Kodak Tri-X on that production, with great results. He chose to shoot certain scenes of this film on Tri-X because it had a sharp contrast that would help fulfill Laughton's vision. The studio however, tried to convince them to shoot on color film instead because they thought it would sell more tickets. Gregory fought to keep it black-and-white: "I could not see this film being in color." The style of the cinematography was split up between the two units: the first unit of the crew shot the scenes in and around the Harpers' home, which were very dark, whereas the second unit shot the scenes traveling along the river, which were designed to look more like images from the children's perspective. One scene in particular that Cortez has spoken about is in the bedroom after Willa has overheard Powell threatening the children. He lit this scene with a halo of light surrounding Willa's head on the pillow, foreshadowing that her death is imminent. Cortez also brought back the Iris shot in one scene, as an homage to silent films.


title: The Night of the Hunter (film)

text: Laughton drew on the harsh, angular look of German expressionist films of the 1920s, which is especially noticeable in the art direction by Hilyard Brown. He had the idea that children notice only certain details of their surroundings that they are focused on, which is why some set pieces are somewhat abstract and minimal: neon lights that are not attached to a particular store, white picket fences that are not surrounding any house, the barn along the river that looks like a painting, and the "chapel-like" parents' bedroom. The river scenes with the children were all shot on a sound stage. The shot of John looking out of the barn window and seeing Powell's silhouette on the horizon was created using a little person and a miniature horse. The underwater scene showing Willa's dead body was shot in a studio using a mannequin with a custom mask to make it look like Winters.


title: The Night of the Hunter (film)

text: The film's score, composed and arranged by Walter Schumann in close association with Laughton, features a combination of nostalgic and expressionistic orchestral passages. The film has two original songs by Schumann, "Lullaby" (sung by Kitty White, whom Schumann discovered in a nightclub) and "Pretty Fly" (originally sung by Sally Jane Bruce as Pearl, but later dubbed by an actress named Betty Benson). A recurring musical device involves the preacher making his presence known by singing the traditional hymn "Leaning on the Everlasting Arms". RCA Victor was impressed by the score, so in 1955 they released a soundtrack with Schumann's score and Laughton narrating an abridged version of the story, also written by Grubb.


title: The Night of the Hunter (film)

text: The film's editor, Robert Golden, has said that after he screened the complete film to one of the United Artists studio executives for the first time, the executive told Golden, "It's too arty."


title: The Night of the Hunter (film)

text: "The Night of the Hunter" premiered on July 26, 1955, in Des Moines, Iowa, a special event to raise money for the YMCA in Gregory's hometown, which included a parade and a broadcast on "The Tonight Show". It later had its premiere in Los Angeles on August 26, 1955, and in New York on September 29, 1955.


title: The Night of the Hunter (film)

text: To promote the film, the "Los Angeles Herald-Express" serialized the film's script throughout April 1955. The film also received an extensive promotional campaign from United Artists, but they weren't sure about the best way to promote it because it didn't fall into any typical film genres, and the promotional material didn't give a good sense of what the film was about. However, one of the film's advertisements won an award for being in the top 50 best advertisements of 1954 from the American Institute of Graphic Arts. According to Paul Gregory, "absolutely no money was spent on promotion...United Artists didn't have the muscle, desire, or intelligence to handle the picture." He originally had the idea to tour the film "road show style", stopping at certain cities that were familiar with Laughton's plays, but he could not convince the studio.


title: The Night of the Hunter (film)

text: The Roman Catholic Diocese of Cheyenne denied the film's release, and Gregory wanted to put together a lawsuit against them, but the studio would not allow him to.


title: The Night of the Hunter (film)

text: "The Night of the Hunter" was a total flop with both audiences and critics at its initial release, and Laughton never directed another film. Bosley Crowther of "The New York Times" called the film "a weird and intriguing endeavor," adding: "unfortunately the story and the thesis presented by Mr. Grubb had to be carried through by Mr. Laughton to a finish—and it is here that he goes wrong. For the evolution of the melodrama, after the threatened, frightened children flee home, angles off into that allegorical contrast of the forces of Evil and Good." Gene Arneel of "Variety" summarized: "The relentless terror of Davis Grubb's novel got away from Paul Gregory and Charles Laughton in their translation of "Night of the Hunter". This start for Gregory as producer and Laughton as director is rich in promise but the completed product, bewitching at times, loses sustained drive via too many offbeat touches that have a misty effect." "Harrison's Reports" wrote, "The picture might have some appeal for those who patronize art houses in search of the unusual in movie fare, but the great majority of those who see it will look upon it as a choppily-edited, foggy melodrama peopled with foggy characters." "Life" summed up the film, "If sometimes it strains too hard at being simple and winds up being pretentious, it still is one of the year's most interesting and provocative films."


title: The Night of the Hunter (film)

text: The Legion of Decency gave the film a B because it degraded marriage, and the Protestant Motion Picture Council rated it "objectionable," saying that any religious person would be offended by it. The film was also banned in Memphis, Tennessee, by the city's head of censorship, Lloyd Binford. Great Britain rated the film "adults only."


title: The Night of the Hunter (film)

text: The film was shot in black and white in the styles and motifs of German Expressionism (bizarre shadows, stylized dialogue, distorted perspectives, surrealistic sets, odd camera angles) to create a simplified and disturbing mood that reflects the sinister character of Powell, the nightmarish fears of the children, and the sweetness of their savior Rachel. Due to the film's visual style and themes, it is also often categorized as a film noir.


title: The Night of the Hunter (film)

text: Laughton took this commercial failure of his first film personally, and never attempted to make another film.


title: The Night of the Hunter (film)

text: At the time of its release, "The Night of the Hunter" received mixed reviews, but over the years it has been reassessed and is now an undisputed classic. It began as a cult film, with a small group of fans, and regularly played at museums and in revival houses. Its popularity grew as a new generation of children were exposed to the film when it played on television. In the 1970s, as the field of film criticism began to expand, many articles were written about the film.


title: The Night of the Hunter (film)

text: Roger Ebert wrote, "It is one of the most frightening of movies, with one of the most unforgettable of villains, and on both of those scores, it holds up ... well after four decades."


title: The Night of the Hunter (film)

text: "The Night of the Hunter" was rated No. 90 on Bravo's 100 Scariest Movie Moments. In a 2007 listing of the 100 Most Beautiful Films, "Cahiers du cinéma" ranked "The Night of the Hunter" No. 2. It is among the top ten in the BFI list of the 50 films you should see by the age of 14. In 2008, it was ranked as the 71st greatest movie of all time by "Empire" magazine in its issue of "The 500 Greatest Movies of All Time".


title: The Night of the Hunter (film)

text: In 1992, the United States Library of Congress deemed "The Night of the Hunter" to be "culturally, historically, or aesthetically significant", and selected the film for preservation in its National Film Registry. On Rotten Tomatoes, the film holds an approval rating of 93% based on , with a weighted average rating of 9.10/10. The site's critical consensus reads, "Featuring Robert Mitchum's formidable performance as a child-hunting preacher, "The Night of the Hunter" is a disturbing look at good and evil."


title: The Night of the Hunter (film)

text: Mark Callaghan, the lead singer for the Australian band The Riptides, parodied Mitchum's character in the music video for the 1982 track, "Hearts And Flowers".


title: The Night of the Hunter (film)

text: Reverend Harry Powell's speech about love and hate has become a memorable moment in film history. In the 1989 Spike Lee film "Do the Right Thing", the character Radio Raheem wears brass knuckles saying "love" and "hate" on each hand and gives a speech that is an almost verbatim copy of Powell's.


title: The Night of the Hunter (film)

text: The Coen brothers have referenced "The Night of the Hunter" in several of their own films, including "The Big Lebowski" (the line "the Dude abides," which is an echo of Rachel's closing line "They abide, and they endure") and "True Grit" (the visual style of Rooster's night ride with Mattie, which is similar to that of John and Pearl's river journey, and the use of the music from "Leaning on the Everlasting Arms").


title: The Night of the Hunter (film)

text: In the episode "Fall" of the television series "Better Call Saul", "The Night of the Hunter" is shown playing in a retirement home as series protagonist Jimmy McGill attempts to deceive a number of his clients. Reverend Powell's hand gestures during his "right hand, left hand" speech are juxtaposed with similar gestures made by Jimmy, highlighting his charismatic but duplicitous nature.


title: The Night of the Hunter (film)

text: In Emerald Fennell's 2020 film "Promising Young Woman" a clip from "The Night of the Hunter" is playing in a scene where the protagonist's parents are watching TV on the couch. In a later scene, the song “The Pretty Fly,” from the soundtrack to "The Night of the Hunter", plays after the protagonist makes a disturbing discovery.


title: The Night of the Hunter (film)

text: "The Night of the Hunter" was released on DVD by MGM Home Entertainment in 2000. On November 16, 2010, the film was released on Blu-ray and DVD by The Criterion Collection in association with the University of California, Los Angeles film archive. Among other supplemental material the Criterion edition includes are various interviews with the cast and crew along with an appearance of the cast on "The Ed Sullivan Show" performing a deleted scene from the film and the two-and-a-half hour documentary "Charles Laughton Directs "The Night of the Hunter"".


title: The Night of the Hunter (film)

text: In 1974, film archivists Robert Gitt and Anthony Slide retrieved several boxes of photographs, sketches, memos, and letters relating to the film from Laughton's widow Elsa Lanchester for the American Film Institute. Lanchester also gave the Institute over 80,000 feet of rushes and outtakes from the filming. In 1981, this material was sent to the UCLA Film and Television Archive where, for the next 20 years, they were edited into a two-and-half hour documentary that premiered in 2002, at UCLA's Festival of Preservation.


title: The Night of the Hunter (film)

text: In 2020, it was reported that Universal Pictures is working on a remake of the film set in the present day, and being written by Matt Orton.


title: Chanel Preston

text: Chanel Preston is an American pornographic actress. She entered the adult film industry in 2010. She was the "Penthouse" magazine Penthouse Pet for March 2012.


title: Chanel Preston

text: Preston was born and raised in Alaska. She is of English, German, and Spanish descent. At age 19 she moved to Hawaii, where she lived for six years. She worked as a stripper for over a year before working in porn. She is also a licensed aesthetician.


title: Chanel Preston

text: Preston entered the adult entertainment industry in January 2010, shooting her first scene with Nick Manning for Vivid Entertainment's Brand New Faces series. Preston has served as president of the Adult Performer Advocacy Committee.


title: Chanel Preston

text: In February 2012, Chanel Preston was announced by "Penthouse" magazine to be their Penthouse Pet for March 2012. In September 2012, Preston appeared in the Russ Irwin music video "Get Me Home".


title: Chanel Preston

text: Preston co-hosted the 31st annual AVN Awards show alongside Samantha Saint on January 18, 2014. Also in 2014, Preston was on CNBC's list of "The Dirty Dozen: Porn's Most Popular Stars". In 2015 she appeared in the "Bust" music video by rapper Waka Flocka Flame.


title: Chanel Preston

text: Also in January 2014, she was featured alongside Dana DeArmond, Asa Akira, and Jessie Andrews in a "Cosmopolitan" article titled "4 Porn Stars on How They Stay Fit". The article was inspired by actress Gabrielle Union's comment made on Conan O'Brien's talk show about striving to follow the fitness routines of the porn stars she saw at her gym. She has also appeared as an extra on "Sons of Anarchy".


title: Chanel Preston

text: In March 2014, Preston launched a sex education based web series titled "Naked With Chanel". According to "Cosmopolitan", the series "examines how our society and upbringing influences our ideas about sex." In order to fund the series, Preston used the fundraising website IndieGogo. Her 2013 campaign generated enough to build the series' website and to film several episodes. She also hosts a sex-positive podcast named "SexThink" with talk show host and political critic, Rob Nelson.


title: Lugh

text: Lugh or Lug (; ) is a figure in Irish mythology. A member of the Tuatha Dé Danann, a group of supernatural beings, Lugh is portrayed as a warrior, a king, a master craftsman and a savior. He is associated with skill and mastery in multiple disciplines, including the arts. Lugh also has associations with oaths, truth and the law, and therefore with rightful kingship. Lugh is linked with the harvest festival of Lughnasadh, which bears his name. His most common epithets are "Lámfada" ("long hand" or "long arm", possibly for his skill with a spear or his ability as a ruler) and "Samildánach" ("equally skilled in many arts").


title: Lugh

text: In mythology, Lugh is the son of Cian and Ethniu (or Ethliu). He is the maternal grandson of the Fomorian tyrant Balor, whom Lugh kills in the "Battle of Mag Tuired". Lugh's son is the hero Cú Chulainn, who is believed to be an incarnation of Lugh.


title: Lugh

text: Lugh has several magical possessions. He wields an unstoppable fiery spear, a sling stone, and owns a hound named "Failinis". He is said to have invented "fidchell", ball games, and horse racing.


title: Lugh

text: He corresponds to the pan-Celtic god Lugus, and his Welsh counterpart is Lleu Llaw Gyffes. He has also been equated with Mercury.


title: Lugh

text: The meaning of Lugh's name is still a matter of debate. Some scholars propose that it derives from a suggested Proto-Indo-European root "*(h2)lewgh-" meaning "to bind by oath" (compare Old Irish "luige" and Welsh "llw", both meaning "oath, vow, act of swearing" and derived from a suffixed Proto-Celtic form, "*lugiyo-", "oath"), suggesting that he was originally a god of oaths and sworn contracts. When Balor meets Lugh in the Second Battle of Moytura he calls Lugh a "babbler". In the past his name was generally believed to come from another suggested Proto-Indo-European root *"leuk-", "flashing light", and since the Victorian era he has often been considered a sun god, similar to the Greco-Roman Apollo. However, the figure of Lugh in Irish mythology and literature seems to be a better match with the Celtic god identified with Mercury, described by Julius Caesar in his "De Bello Gallico". There are serious phonological issues with deriving the name from "*leuk-", notably that Proto-Indo-European ' never produced Proto-Celtic '; for this reason most modern specialists in Celtic languages no longer accept this etymology.


title: Lugh

text: Lugh is typically described as a youthful warrior. In the brief narrative "Baile in Scáil" Lugh is described as being very large and very beautiful and also as a spear-wielding horseman.


title: Lugh

text: A man fair and tall, with a great head of curly yellow hair. He has a green mantle wrapped about him and a brooch of white silver in the mantle over his breast. Next to his white skin, he wears a tunic of royal satin with red-gold insertion reaching to his knees. He carries a black shield with a hard boss of white-bronze. In his hand a five-pointed spear and next to it a forked javelin. Wonderful is the play and sport and diversion that he makes (with these weapons). But none accosts him and he accosts none as if no one could see him.


title: Lugh

text: Elsewhere Lugh is described as a tall young man with bright red cheeks, white sides, a bronze-coloured face and blood-coloured hair.


title: Lugh

text: Finally, in "The Fate of the Children of Turenn" Lugh's appearance is compared to the sun on several occasions. He is described by Bres as follows:


title: Lugh

text: Then arose Breas, the son of Balar, and he said: "It is a wonder to me", said he, "that the sun to rise in the west today, and in the east every other day". "It would be better that it wer so", said the Druids. "What else is it?" said he. "The radiance of the face of Lugh of the Long Arms", said they.


title: Lugh

text: ...they were not long there when they saw an army and a goodly host coming towards them from the East, and in the vanguard there was one young man high in authority over all; and like to the setting sun was the radiance of his face and forehead, and they were unable to gaze upon his countenance on account of its splendour. And this is who it was - Lugh Lamhfhada Loinnbheimionach...from the Land of Promise...and when the "Cathbarr" (Manannan's helmet) was let off of him the appearance of his face and forehead was as brilliant as the sun on a dry summer's day.


title: Lugh

text: Lugh's father is Cian of the Tuatha Dé Danann, and his mother is Ethniu (Eithne in Modern Irish), daughter of Balor of the Fomorians. In "Cath Maige Tuired" their union is a dynastic marriage following an alliance between the Tuatha Dé and the Fomorians. In the "Lebor Gabála Érenn," Cian gives the boy to Tailtiu, queen of the Fir Bolg, in fosterage. In the Dindsenchas, Lugh, the foster-son of Tailtiu, is described as the "son of the Dumb Champion". In the poem Baile Suthain Sith Eamhna Lugh is called "descendant of the poet."


title: Lugh

text: A folktale told to John O'Donovan by Shane O'Dugan of Tory Island in 1835 recounts the birth of a grandson of Balor who grows up to kill his grandfather. The grandson is unnamed, his father is called Mac Cinnfhaelaidh and the manner of his killing of Balor is different, but it has been taken as a version of the birth of Lugh, and was adapted as such by Lady Gregory. In this tale, Balor hears a druid's prophecy that he will be killed by his own grandson. To prevent this he imprisons his only daughter in the Tór Mór (great tower) of Tory Island. She is cared for by twelve women, who are to prevent her ever meeting or even learning of the existence of men. On the mainland, Mac Cinnfhaelaidh owns a magic cow who gives such abundant milk that everyone, including Balor, wants to possess her. While the cow is in the care of Mac Cinnfhaelaidh's brother Mac Samthainn, Balor appears in the form of a little red-haired boy and tricks him into giving him the cow. Looking for revenge, Mac Cinnfhaelaidh calls on a "leanan sídhe" (fairy woman) called Biróg, who transports him by magic to the top of Balor's tower, where he seduces Ethniu. In time she gives birth to triplets, which Balor gathers up in a sheet and sends to be drowned in a whirlpool. The messenger drowns two of the babies but unwittingly drops one child into the harbour, where he is rescued by Biróg. She takes him to his father, who gives him to his brother, Gavida the smith, in fosterage.


title: Lugh

text: There may be further triplism associated with his birth. His father in the folktale is one of a triad of brothers, Mac Cinnfhaelaidh, Gavida, and Mac Samthainn, whereas in the "Lebor Gabála", his father Cian is mentioned alongside his brothers Cú and Cethen. Two characters called Lugaid, a popular medieval Irish name thought to derive from Lugh, have three fathers: Lugaid Riab nDerg (Lugaid of the Red Stripes) was the son of the three "Findemna" or fair triplets, and Lugaid mac Con Roí was also known as "mac Trí Con", "son of three hounds". In Ireland's other great "sequestered maiden" story, the tragedy of Deirdre, the king's intended is carried off by three brothers, who are hunters with hounds. The canine imagery continues with Cian's brother Cú ("hound"), another Lugaid, Lugaid Mac Con (son of a hound), and Lugh's son Cúchulainn ("Culann's Hound"). A fourth Lugaid was Lugaid Loígde, a legendary King of Tara and ancestor of (or inspiration for) Lugaid Mac Con.


title: Lugh

text: As a young man Lugh travels to Tara to join the court of King Nuada of the Tuatha Dé Danann. The doorkeeper will not let him in unless he has a skill he can use to serve the king. He offers his services as a wright, a smith, a champion, a swordsman, a harpist, a hero, a poet, historian, a sorcerer, and a craftsman, but each time is rejected as the Tuatha Dé Danann already have someone with that skill. When Lugh asks if they have anyone with all those skills simultaneously, the doorkeeper has to admit defeat, and Lugh joins the court and is appointed Chief Ollam of Ireland. He wins a flagstone-throwing contest against Ogma, the champion, and entertains the court with his harp. The Tuatha Dé Danann are, at that time, oppressed by the Fomorians, and Lugh is amazed how meekly they accept their oppression. Nuada wonders if this young man could lead them to freedom. Lugh is given command over the Tuatha Dé Danann, and he begins making preparations for war.


title: Lugh

text: Tuireann and Cian, Lugh's father, are old enemies, and one day his sons, Brian, Iuchar, and Iucharba spot Cian in the distance and decide to kill him. They find him hiding in the form of a pig, but Cian tricked the brothers into allowing him to transform back to a man before they killed him, giving Lugh the legal right to claim compensation for a father rather than just a pig. When they try to bury him, the ground spits his body back twice before keeping him down, and eventually confesses that it is a grave to Lugh. Lugh holds a feast and invites the brothers, and during it he asks them what they would demand as compensation for the murder of their father. They reply that death would be the only just demand, and Lugh agrees. He then accuses them of the murder of his father, Cian, and sets them a series of seemingly impossible quests. The brothers go on an adventure and achieve them all except the last one, which will surely kill them. Despite Tuireann's pleas, Lugh demands that they proceed and, when they are all fatally wounded, he denies them the use of one of the items they have retrieved, a magic pigskin which heals all wounds. They die of their wounds and Tuireann dies of grief over their bodies.


title: Lugh

text: Using the magic artefacts the sons of Tuireann have gathered, Lugh leads the Tuatha Dé Danann in the Second Battle of Mag Tuireadh against the Fomorians. Prior to the battle Lugh asks each man and woman in his army what art he or she will bring to the fray; he then addressed his army in speech, which elevated each warrior's spirit to that of a king or lord. Nuada is killed in the battle by Balor. Lugh faces Balor, who opens his terrible, poisonous eye that kills all it looks upon, but Lugh shoots a sling-stone that drives his eye out the back of his head, killing Balor and wreaking havoc on the Fomorian army behind. After the victory Lugh finds Bres, the half-Fomorian former king of the Tuatha Dé Danann, alone and unprotected on the battlefield, and Bres begs for his life. If he is spared, he promises, he will ensure that the cows of Ireland always give milk. The Tuatha Dé Danann refuse the offer. He then promises four harvests a year, but the Tuatha Dé Danann say one harvest a year suits them. But Lugh spares his life on the condition that he teach the Tuatha Dé Danann how and when to plough, sow, and reap.


title: Lugh

text: Lugh instituted an event similar to the Olympic games called the Assembly of Talti which finished on Lughnasadh (1 August) in memory of his foster-mother, Tailtiu, at the town that bears her name (now Teltown, County Meath). He likewise instituted Lughnasadh fairs in the areas of Carman and Naas in honour of Carman and Nás, the eponymous tutelary goddesses of these two regions. Horse races and displays of martial arts were important activities at all three fairs. However, Lughnasadh itself is a celebration of Lugh's triumph over the spirits of the Otherworld who had tried to keep the harvest for themselves. It survived long into Christian times and is still celebrated under a variety of names. "Lúnasa" is now the Irish name for the month of August.


title: Lugh

text: According to a poem of the "dindsenchas", Lugh was responsible for the death of Bres. He made 300 wooden cows and filled them with a bitter, poisonous red liquid which was then "milked" into pails and offered to Bres to drink. Bres, who was under an obligation not to refuse hospitality, drank it down without flinching, and it killed him.


title: Lugh

text: One of his wives, Buach, had an affair with Cermait, son of the Dagda. Lugh killed him in revenge, but Cermait's sons, Mac Cuill, Mac Cecht, and Mac Gréine, killed Lugh in return, spearing him through the foot then drowning him in Loch Lugborta in County Westmeath He had ruled for forty years. Cermait was later revived by his father, the Dagda, who used the smooth or healing end of his staff to bring Cermait back to life.


title: Lugh

text: Lugh is given the matriname "mac Ethlenn" or "mac Ethnenn" ("son of Ethliu or Ethniu", his mother) and the patriname "mac Cein" ("son of Cian", his father). He is the maternal grandson of the Fomorian tyrant Balor, whom Lugh kills in the "Battle of Mag Tuired". Lugh's son is the hero Cú Chulainn, who is believed to be an incarnation of Lugh.


title: Lugh

text: He had several wives, including Buí (AKA Buach or Bua "Victory") and Nás, daughters of Ruadri Ruad, king of Britain. Buí lived and was buried at Knowth (Cnogba). Nás was buried at Naas, County Kildare, which is named after her. Lugh had a son, Ibic "of the horses", by Nás. It is said that Nás dies with the noise of combat, therefore it is difficult to know where she dies. Lugh's daughter or sister was Ebliu, who married Fintan. By the mortal Deichtine, Lugh was father to the hero Cú Chulainn.


title: Lugh

text: Lugh possessed a number of magical items, retrieved by the sons of Tuirill Piccreo in Middle Irish redactions of the Lebor Gabála. Not all the items are listed here. The late narrative "Fate of the Children of Tuireann" not only gives a list of items gathered for Lugh, but also endows him with such gifts from the sea god Manannán as the sword Fragarach, the horse Enbarr (Aonbarr), the boat / ("Wave-Sweeper"), his armour and helmet.


title: Lugh

text: Lugh's spear (), according to the text of The Four Jewels of the Tuatha Dé Danann, was said to be impossible to overcome, taken to Ireland from Gorias (or Findias).


title: Lugh

text: Lugh obtained the Spear of Assal () as fine () imposed on the children of Tuirill Piccreo (or Biccreo), according to the short account in which adds that the incantation "Ibar (Yew)" made the cast always hit its mark, and "Athibar (Re-Yew)" caused the spear to return.


title: Lugh

text: In a full narrative version called (The Fate of the Children of Tuireann), from copies no earlier than the 17th century, Lugh demands the spear named "Ar-éadbair" or "Areadbhair" (Early Modern Irish: ) which belonged to Pisear, king of Persia. Areadbhair's tip had to be kept immersed in a pot of water to keep it from igniting, a property similar to the Lúin of Celtchar. This spear is also called "Slaughterer" in translation.


title: Lugh

text: There is yet another name that Lugh's spear goes by: "A [yew] tree, the finest of the wood" (Early Modern Irish: ), occurring in an inserted verse within "The Fate of the Children of Tuireann". "The famous yew of the wood" () is also the name that Lugh's spear is given in a tract which alleges that it, the Lúin of Celtchar and the spear Crimall that blinded Cormac Mac Airt were one and the same weapon (tract in TCD MS 1336 (H 3. 17), col. 723, discussed in the Lúin page).


title: Lugh

text: Lugh's projectile weapon, whether a dart or missile, was envisioned to be symbolic of lightning-weapon.


title: Lugh

text: Lugh's sling rod, named "Lugh's Chain", was the rainbow and the Milky Way, according to popular writer Charles Squire. Squire adds that Lugh's spear which needed no wielding was alive and thirsted so for blood that only by steeping its head in a sleeping-draught of pounded fresh poppy leaves could it be kept at rest. When battle was near, it was drawn out; then it roared and struggled against its thongs, fire flashed from it, and it tore through the ranks of the enemy once slipped from the leash, never tired of slaying.


title: Lugh

text: According to the brief accounts in the Lebor Gabála Érenn, Lugh used the "sling-stone" ("cloich tabaill") to slay his grandfather, Balor the Strong-Smiter in the Battle of Magh Tuired. The narrative , preserved in a unique 16th century copy, words it slightly different saying that Lugh used the sling-stone to destroy the evil eye of Balor of the Piercing Eye (Bolur Birugderc).


title: Lugh

text: The ammunition that Lugh used was not just a stone, but a "tathlum" according to a certain poem in Egerton MS. 1782 (olim W. Monck Mason MS.), the first quatrain of which is as follows:


title: Lugh

text: The poem goes on to describe the composition of this tathlum, as being formed from the bloods collected from toads, bears, the lion, vipers and the neck-base of Osmuinn, mixed with the sands of the Armorian Sea and the Red Sea.


title: Lugh

text: Lugh is also seen girt with the Freagarthach (better known as Fragarach), the sword of Manannán, in the assembly of the Tuatha Dé Danann in the "Fate of the Children of Tuireann".


title: Lugh

text: Lugh had a horse named Aenbharr which could fare over both land and sea. Like much of his equipment, it was furnished to him by the sea god Manannán mac Lir. When the Children of Tuireann asked to borrow this horse, Lugh begrudged them, saying it would not be proper to make a loan of a loan. Consequently, Lugh was unable to refuse their request to use Lugh's currach (coracle) or boat, the "Wave-Sweeper" ().


title: Lugh

text: In the Lebor Gabála, Gainne and Rea were the names of the pair of horses belonging to the king of the isle of Sicily [on the (Tyrrhene sea)], which Lug demanded as éraic from the sons of Tuirill Briccreo.


title: Lugh

text: Failinis was the name of the whelp of the King of Ioruaidhe that Lugh demanded as éiric (a forfeit) in the "Oidhead Chloinne Tuireann". This concurs with the name of the hound mentioned in an "Ossianic Ballad", sometimes referred to by its opening line " (They came here as a band of three)". In the ballad, the hound is called Ṡalinnis (Shalinnis) or Failinis (in the Lismore text), and belonged to a threesome from Iruaide whom the Fianna encounter. It is described as "the ancient grayhound... that had been with Lugh of the Mantles, / Given him by the sons of Tuireann Bicreann"


title: Lugh

text: Lugh corresponds to the pan-Celtic god Lugus, and his Welsh counterpart is Lleu Llaw Gyffes. He has also been equated with Mercury. Sometimes he is interpreted as a storm god and, less often today, as a sun god. Others have noted a similarity in Lugh's slaying of Balor to the slaying of Baldr by Loki. Lugh's mastery of all arts has led many to link him with the unnamed Gaulish god Julius Caesar identifies with Mercury, whom he describes as the "inventor of all the arts". Caesar describes the Gaulish Mercury as the most revered deity in Gaul, overseeing journeys and business transactions.


title: Lugh

text: The County of Louth in Ireland is named after the village of Louth, which is named after the god Lugh. Historically, the place name has had various spellings; "Lugmad", "Lughmhaigh", and "Lughmhadh" (see Historic Names List, for full listing). "Lú" is the modern simplified spelling. Other places named for Lugh include the cairn at Seelewey (Suidhe Lughaidh, or Lug's Seat), Dunlewey, and Rath-Lugaidh in Carney, Sligo. Seelewey was located in Moyturra Chonlainn and, according to local folklore, was a place where giants used to gather in olden days.


title: Lugh

text: The modern city of Lyon was founded as "Colonia Copia Felix Munatia" in 43 BC, but by the end of the first century AD had come to be known as "Lugdunum", a Latinized variant of the ancient Gaulish name *Lugudunon, meaning "Fortress of Lugh".


title: Marital rape

text: Marital rape or spousal rape is the act of sexual intercourse with one's spouse without the spouse's consent. The lack of consent is the essential element and need not involve physical violence. Marital rape is considered a form of domestic violence and sexual abuse. Although, historically, sexual intercourse within marriage was regarded as a right of spouses, engaging in the act without the spouse's consent is now widely classified as rape by many societies around the world, repudiated by international conventions, and increasingly criminalized.


title: Marital rape

text: The issues of sexual and domestic violence within marriage and the family unit, and more specifically, the issue of violence against women, have come to growing international attention from the second half of the 20th century. Still, in many countries, marital rape either remains outside the criminal law, or is illegal but widely tolerated. Laws are rarely being enforced, due to factors ranging from reluctance of authorities to pursue the crime, to lack of public knowledge that sexual intercourse in marriage without consent is illegal.


title: Marital rape

text: Marital rape is more widely experienced by women, though not exclusively. Marital rape is often a chronic form of violence for the victim which takes place within abusive relations. It exists in a complex web of state governments, cultural practices, and societal ideologies which combine to influence each distinct instance and situation in varying ways. The reluctance to define non-consensual sex between married couples as a crime and to prosecute has been attributed to traditional views of marriage, interpretations of religious doctrines, ideas about male and female sexuality, and to cultural expectations of subordination of a wife to her husband—views which continue to be common in many parts of the world. These views of marriage and sexuality started to be challenged in most Western countries from the 1960s and 70s especially by second-wave feminism, leading to an acknowledgment of the woman's right to self-determination of all matters relating to her body, and the withdrawal of the exemption or defense of marital rape.


title: Marital rape

text: Most countries criminalized marital rape from the late 20th century onward—very few legal systems allowed for the prosecution of rape within marriage before the 1970s. Criminalization has occurred through various ways, including removal of statutory exemptions from the definitions of rape, judicial decisions, explicit legislative reference in statutory law preventing the use of marriage as a defense, or creation of a specific offense of marital rape. In many countries, it is still unclear whether marital rape is covered by the ordinary rape laws, but in some countries non-consensual sexual relations involving coercion may be prosecuted under general statutes prohibiting violence, such as assault and battery laws.


title: Marital rape

text: Historically, in much of the world, rape was seen as a crime or tort of theft of a man's property (usually either a husband or father). In this case, property damage meant that the crime was not legally recognized as damage against the victim, but instead to her father or husband's property. Therefore, by definition a husband could not rape his wife. The view that a husband cannot be charged with the rape of his wife was described by Sir Matthew Hale (1609–1676) in "History of the Pleas of the Crown", published posthumously in 1736, where he wrote that "The husband cannot be guilty of a rape committed by himself upon his lawful wife, for by their mutual consent and contract the wife hath given up herself in this kind unto her husband, which she cannot retract". Also, American and English law subscribed until the 20th century to the system of coverture, that is, a legal doctrine under which, upon marriage, a woman's legal rights were subsumed by those of her husband. The implication was that once unified by marriage, a spouse could no longer be charged with raping one's spouse, anymore than be charged with raping oneself.


title: Marital rape

text: Many jurisdictions, including all fifty U.S. states, had criminalized marital rape by the 1990s. English common law also had a great impact on many legal systems of the world through colonialism.


title: Marital rape

text: Kersti Yllö states in the prologue of "Understanding Marital Rape In a Global Context", "In some cultures, consent is not even something that an individual wife can give. The families that arranged the marriage guarantee her permanent consent." Control over a wife's sexuality was only a part of the greater control that men had in all other areas concerning her. A husband's control over his wife's body could also be seen in the way adultery between a wife and another man was constructed; for example in 1707, English Lord Chief Justice John Holt described the act of a man having sexual relations with another man's wife as "the highest invasion of property". For this reason, in many cultures there was a conflation between the crimes of rape and adultery, since both were seen and understood as a violation of the rights of the husband. Spousal rape was considered a property crime against a husband, not against a woman's right to self-determination.


title: Marital rape

text: The property to be withheld in a female was her virginity; this was the commodity (Bergen, 2016). Following this line of logic, a woman was (and still is in many cultures across the globe) first the property of her father, then, upon marriage, the property of her husband (Bergen, 2016). Therefore, a man could not be prosecuted for raping his own wife because she was his possession (Schelong, 1994). However, if another man raped someone's wife, this was essentially stealing property (a women's sexuality) (Bergen, 2016). In English customs, "bride capture" (a man claiming a woman through rape) was thought to be stealing a father's property by raping his daughter. Therefore, rape laws were created to "…protect the property interests men had in their women, not to protect women themselves" (Schelong, 1994). This concept of women as property permeates current marital rape ideology and laws throughout the globe.


title: Marital rape

text: In some cultures, marriage is arranged for the purpose of creating access to procreation (Yllö, 2016). In these situations, the parties do not necessarily consent to marriage (in the case of forced marriage) (Yllö, 2016). Following this logic, if consent is not part of marriage, then it is not necessary for intercourse. The autonomy of the wife is also often compromised in cultures where bride price is paid. Under customary law in certain parts of Africa, forced sex in marriage was not prohibited, although some specific circumstances, such as during advanced pregnancy, immediately after childbirth, during menstruation, or during mourning for a deceased close relative, were recognized as giving the wife the right to refuse sex.


title: Marital rape

text: Rape has been, until recent decades, understood as a crime against honor and reputation – not only in domestic legislation, but also in international law; for example according to the Article 27 of the Fourth Geneva Convention, "Women shall be especially protected against any attack on their honour, in particular against rape, enforced prostitution, or any form of indecent assault". It was not until the 1990s that the ICC statute recognized crimes of sexual violence as violent crimes against the person; "Not until the last half century was rape understood to be an offense against the woman, against her dignity, instead of against her family's or her husband's honor".


title: Marital rape

text: Historically, many cultures have had a concept of spouses' conjugal rights to sexual intercourse with each other. This can be seen in English common law, in force in Anglo America and the British Commonwealth, where the very concept of marital rape was treated as an impossibility. This was illustrated most vividly by Sir Matthew Hale, (1609-1676), in his legal treatise "Historia Placitorum Coronæ" or "History of the Pleas of the Crown" (posthumously, 1736) where he wrote that "The husband cannot be guilty of a rape committed by himself upon his lawful wife, for by their mutual consent and contract the wife hath given up herself in this kind unto her husband, which she cannot retract."


title: Marital rape

text: Sir Matthew Hale's statement in "History of the Pleas of the Crown" did not cite a legal precedent for it, though it relied on earlier standards. In a case of Lord Audley's (1488–1544), for instance, Hale cite's the jurist Bracton (c. 1210 – c. 1268) support of this rule, said to have derived from laws of King Æthelstan (r. 927–939) where upon the law holds that even "were the party of no chaste life, but a whore, yet there may be ravishment: but it is a good plea to say she was his concubine". A lawful marriage legitimizes the conjugal act itself, so "marital rape" is a contradiction in terms. While a physical assault against a spouse may be charged, such is distinct from the delegitimization of conjugal union itself as rape. Marriage then should not be defined as an "exemption" to rape but as "contradictory" to it. Marriage created conjugal rights between spouses, and marriage could not be annulled except by a private Act of Parliament—it therefore follows that a spouse could not revoke conjugal rights from the marriage, and therefore there could be no rape between spouses. The principle was repeated in East's "Treatise of the Pleas of the Crown" in 1803 and in Archbold's "Pleading and Evidence in Criminal Cases" in 1822. The principle was framed as an exemption to the law of rape in an English courtroom in "R v Clarence", but it was not overturned until 1991 by the House of Lords in the case of "R. v. R" in 1991, where it was described as an anachronistic and offensive legal fiction.


title: Marital rape

text: From the beginnings of the 19th century feminist movement, activists challenged the presumed right of men to engage in forced or coerced sex with their wives. In the United States, "the nineteenth-century woman's rights movement fought against a husband's right to control marital intercourse in a campaign that was remarkably developed, prolific, and insistent, given nineteenth-century taboos against the public mention of sex or sexuality." Suffragists including Elizabeth Cady Stanton and Lucy Stone "singled out a woman's right to control marital intercourse as the core component of equality."


title: Marital rape

text: Nineteenth century feminist demands centered on the right of women to control their bodies and fertility, positioned consent in marital sexual relations as an alternative to contraception and abortion (which many opposed), and also embraced eugenic concerns about excessive procreation. British liberal feminists John Stuart Mill and Harriet Taylor attacked marital rape as a gross double standard in law and as central to the subordination of women.


title: Marital rape

text: Advocates of the Free Love Movement, including early anarcha-feminists such as Voltairine de Cleyre and Emma Goldman, as well as Victoria Woodhull, Thomas Low Nichols, and Mary Gove Nichols, joined a critique of marital rape to advocate women's autonomy and sexual pleasure. Moses Harman, a Kansas-based publisher and advocate for women's rights, was jailed twice under the Comstock laws for publishing articles (by a woman who was victimized and a doctor who treated marital rape survivors) decrying marital rape. De Cleyre defended Harman in a well-known article, "Sexual Slavery." She refused to draw any distinction between rape outside of and within marriage: "And that is rape, where a man forces himself sexually upon a woman whether he is licensed by the marriage law to do it or not."


title: Marital rape

text: British philosopher and writer Bertrand Russell in his book "Marriage and Morals" (1929) deplored the situation of married women. He wrote "Marriage is for woman the commonest mode of livelihood, and the total amount of undesired sex endured by women is probably greater in marriage than in prostitution."


title: Marital rape

text: The marital rape exemption or defence became more widely viewed as inconsistent with the developing concepts of human rights and equality. Feminists worked systematically since the 1960s to overturn the marital rape exemption and criminalize marital rape. Increasing criminalization of spousal rape is part of a worldwide reclassification of sexual crimes "from offenses against morality, the family, good customs, honor, or chastity ... to offenses against liberty, self-determination, or physical integrity." In December 1993, the United Nations High Commissioner for Human Rights published the "Declaration on the Elimination of Violence Against Women". This establishes marital rape as a human rights violation.


title: Marital rape

text: The importance of the right to self sexual determination of women is increasingly being recognized as crucial to women's rights. In 2012, High Commissioner for Human Rights Navi Pillay stated that:


title: Marital rape

text: Despite these trends and international moves, criminalization has not occurred in all UN member States. Determining the criminal status of marital rape may be challenging, because, while some countries "explicitly criminalize" the act (by stipulating in their rape laws that marriage is not a defense to a charge of rape; or by creating a specific crime of 'marital rape'; or, otherwise, by having statutory provisions that expressly state that a spouse can be charged with the rape of their other spouse) and other countries "explicitly exempt" spouses (by defining rape as forced sexual intercourse outside of marriage; or forced sexual intercourse with a woman not the perpetrator's wife; or by providing in their rape provisions that marriage is a defense to a charge of rape), in many countries the ordinary rape laws are silent on the issue (that is, they do not address the issue one way or another)—in such cases, in order to determine whether marital rape is covered by the ordinary rape laws it must be analyzed whether there are judicial decisions in this respect; and former definitions of the law are also important (for instance whether there was previously a statutory exemption that was removed by legislators for the purpose of implicitly including marital rape).


title: Marital rape

text: In 2006, the UN Secretary-General's in-depth study on all forms of violence against women stated that (page 113):


title: Marital rape

text: In 2011, the UN Women report Progress of the World's Women:In Pursuit of Justice stated that (page 17):


title: Marital rape

text: Traditionally, rape was a criminal offense that could only be committed outside marriage, and courts did not apply the rape statutes to acts of forced sex between spouses. With changing social views, and international condemnation of sexual violence in marriage, courts have started to apply the rape laws in marriage. The current applicability in many countries of rape laws to spouses is currently unclear, since in many countries the laws have not been recently tested in court. In some countries, notably jurisdictions which have inherited the 1860 Indian Penal Code (such as Singapore, India, Bangladesh, Sri Lanka, Burma) and some countries in the Commonwealth Caribbean region, the laws explicitly exempt spouses from prosecution (for instance, under the 1860 Indian Penal Code, which has also been inherited by other countries in the region, the law on rape states that "Sexual intercourse by a man with his own wife is not rape").


title: Marital rape

text: An example of a country where the rape law "explicitly excludes" a husband as a possible perpetrator is Ethiopia; its rape law states: "Article 620 - Rape: Whoever compels a woman to submit to sexual intercourse "outside wedlock", whether by the use of violence or grave intimidation, or after having rendered her unconscious or incapable of resistance, is punishable with rigorous imprisonment from five years to fifteen years". Another example is South Sudan, where the law states: "Sexual intercourse by a married couple is not rape, within the meaning of this section". (Art 247). Conversely, an example of country where the rape law "explicitly criminalizes" marital rape is Namibia - The Combating of Rape Act (No. 8 of 2000) states that: "No marriage or other relationship shall constitute a defence to a charge of rape under this Act". An example of a jurisdiction where marital rape is a "distinct" criminal offense is Bhutan where 'Marital rape' is defined by Article 199 which reads: "A defendant shall be guilty of marital rape, if the defendant engages in sexual intercourse with one's own spouse without consent or against the will of the other spouse".


title: Marital rape

text: By 1986, in Europe, there was international pressure to criminalize marital rape: the "European Parliament's Resolution on Violence Against Women of 1986" called for its criminalization. This was reiterated by the Recommendation Rec(2002)5 of the Committee of Ministers to member states on the protection of women against violence. (see para 35) This recommendation provided detailed guidelines on how legislation regarding domestic violence, rape, and other forms of violence against women should operate. It also provided a definition of violence against women, and gave a list of non-exhaustive examples, including marital rape (see section "Definition" para 1). Although the approach on the issue of violence against women has varied significantly among European countries, the traditional view that acts of violence against a woman are crimes against honor and morality, and not against the self-determination of the woman, was still prevalent in the 1990s in many countries. The above recommendation stated that member states must "ensure that criminal law provides that any act of violence against a person, in particular physical or sexual violence, constitutes a violation of that person's physical, psychological and/or sexual freedom and integrity, and not solely a violation of morality, honour or decency" (para 34). The approach regarding sexual and other forms of violence against women in specific European countries did not necessarily mirror women's rights in other areas of life (such as public or political life) in those countries: in fact some countries otherwise known for advanced women's rights, such as Finland and Denmark, have received strong criticism for their policies in this area. A 2008 report produced by Amnesty International, described Danish laws on sexual violence as "inconsistent with international human rights standards", which has led to Denmark eventually reforming its sexual offenses legislation in 2013. (Until 2013, in Denmark "the Penal Code reduce[d] the level of penalty or provide[d] for exclusion of punishment altogether for rape and sexual violence within marriage in certain instances [...] and if the perpetrator enter[ed] into or continu[ed] a marriage with his victim the punishment for rape c[ould] be reduced or remitted"). Cultural and religious values which support female subordination and inequality are considered important in dealing with the issue of sexual violence against women; but there have been calls for analyses of cultural gender norms which tolerate violence against women to not be based on stereotypes; Mala Htun and S. Laurel Weldon write "gender policy is not one issue but many" and "When [...] Latin American countries are quicker to adopt policies addressing violence against women than the Nordic countries, one at least ought to consider the possibility that fresh ways of grouping states would further the study of gender politics." The causes of the toleration - in law or in practice - of sexual violence inside marriage are complex; lack of understanding of the concept of consent and coercion due to lack of sexual education and public discussion about sexuality are often cited as causes of sexual abuse in general; but there has been criticism towards the idea that sex education about consent, in and of itself, is sufficient.


title: Marital rape

text: The countries which choose to ratify the Council of Europe Convention on preventing and combating violence against women and domestic violence, the first legally binding instrument in Europe in the field of violence against women, are bound by its provisions to ensure that non-consensual sexual acts committed against a spouse or partner are illegal. The convention came into force in August 2014. In its explanatory report (para 219) it acknowledges the long tradition of toleration, "de jure" or "de facto", of marital rape and domestic violence:


title: Marital rape

text: Countries which were early to criminalize marital rape include the Soviet Union (1922), Poland (1932), Czechoslovakia (1950), some other members of the Communist Bloc, Sweden (1965), and Norway (1971). Slovenia, then a republic within federal Yugoslavia, criminalized marital rape in 1977. The Israeli Supreme Court affirmed that marital rape is a crime in a 1980 decision, citing law based on the Talmud (at least 6th century). Criminalization in Australia began with the state of New South Wales in 1981, followed by all other states from 1985 to 1992. Several formerly British-ruled countries followed suit: Canada (1983), New Zealand (1985), and Ireland (1990).


title: Marital rape

text: Marital rape was criminalized in Austria in 1989 (and in 2004 it became a state offense meaning it can be prosecuted by the state even in the absence of a complaint from the spouse, with procedures being similar to stranger rape). In Switzerland marital rape became a crime in 1992 (and became a state offense in 2004). In Spain, the Supreme Court ruled in 1992 that sex within marriage must be consensual and that sexuality in marriage must be understood in light of the principle of the freedom to make one's own decisions with respect to sexual activity; in doing so it upheld the conviction of a man who had been found guilty of raping his wife by a lower court.


title: Marital rape

text: In Europe, Finland outlawed marital rape in 1994. The case of domestic violence in Finland has been the subject of interest and discussion, because Finland is otherwise considered a country where women have very advanced rights in regard to "public" life and participation in the public sphere (jobs, opportunities, etc.). The country has been made the object of international criticism in regard to its approach towards violence against women. A 2010 Eurobarometer survey on European attitudes on violence against women showed that victim blaming attitudes are much more common in Finland than in other countries: 74% of Finns blamed "the provocative behaviour of women" for violence against women, much higher than in other countries (for instance many countries that are popularly believed to be among the most patriarchal of Europe were significantly less likely to agree with that assertion: 33% in Spain, 46% in Ireland, 47% in Italy).


title: Marital rape

text: Belgium was early to criminalize marital rape. In 1979, the Brussels Court of Appeal recognized marital rape and found that a husband who used serious violence to coerce his wife into having sex against her wishes was guilty of the criminal offense of rape. The logic of the court was that, although the husband did have a 'right' to sex with his wife, he could not use violence to claim it, as Belgian laws did not allow people to obtain their rights by violence. In 1989 laws were amended, the definition of rape was broadened, and marital rape began to be treated the same as other forms of rape.


title: Marital rape

text: In Ireland, the Criminal Law (Rape) Act, 1981 defined rape as "unlawful sexual intercourse" without consent; an attempt to explicitly include spouses within the definition was rejected by the Fianna Fáil government. Seán Doherty, the Minister for Justice, suggested that the courts might allow a charge of rape in some cases, and that various assault charges might be prosecuted in others. A 1987 discussion paper by the Law Reform Commission stated, "In the absence of Irish decisions on the topic, the present law cannot be stated with any great degree of confidence. It would appear, however, that to the extent that the marital rape exemption exists, it is confined to circumstances where the spouses are cohabiting and there are no separation proceedings in being, or even, perhaps, in contemplation." The paper's call to abolish any marital exemption was "on the whole, generally welcomed, although some misgivings were expressed as to whether it might not lead to fabricated complaints and unwarranted intrusions in the marital relationship." The Criminal Law (Rape) (Amendment) Act, 1990 removed the word "unlawful" from the 1981 definition of rape, and abolished "any rule of law by virtue of which a husband cannot be guilty of the rape of his wife". The first two convictions were in 2006 (upon retrial) and 2016.


title: Marital rape

text: In France, in 1990, following a case where a man had tortured and raped his wife, the Court of Cassation authorized prosecution of spouses for rape or sexual assault. In 1992 the Court convicted a man of the rape of his wife, stating that the presumption that spouses have consented to sexual acts that occur within marriage is only valid when the contrary is not proven. In 1994, Law 94-89 criminalized marital rape; a second law, passed 4 April 2006, makes rape by a partner (including in unmarried relationships, marriages, and civil unions) an aggravating circumstance in prosecuting rape.


title: Marital rape

text: Germany outlawed spousal rape in 1997, which is later than other developed countries. Female ministers and women's rights activists lobbied for this law for over 25 years. Before 1997, the definition of rape was: ""Whoever compels a woman to have extramarital intercourse with him, or with a third person, by force or the threat of present danger to life or limb, shall be punished by not less than two years’ imprisonment"". In 1997 there were changes to the rape law, broadening the definition, making it gender-neutral, and removing the marital exemption. Before, marital rape could only be prosecuted as "Causing bodily harm" (Section 223 of the German Criminal Code), "Insult" (Section 185 of the German Criminal Code) and "Using threats or force to cause a person to do, suffer or omit an act" (Nötigung, Section 240 of the German Criminal Code) which carried lower sentences and were rarely prosecuted.


title: Marital rape

text: Before a new Criminal Code came into force in 2003, the law on rape in Bosnia and Herzegovina also contained a statutory exemption, and read: ""Whoever coerces a female not his wife into sexual intercourse by force or threat of imminent attack upon her life or body or the life or body of a person close to her, shall be sentenced to a prison term of one to ten years"". In Portugal also, before 1982, there was a statutory exemption.


title: Marital rape

text: Marital rape was criminalized in Serbia in 2002; before that date rape was legally defined as forced sexual intercourse outside of marriage. The same was true in Hungary until 1997.


title: Marital rape

text: In 1994, in Judgment no. 223/94 V, 1994, the Court of Appeal of Luxembourg confirmed the applicability of the provisions of the Criminal Code regarding rape to marital rape.


title: Marital rape

text: Marital rape was made illegal in the Netherlands in 1991. The legislative changes provided a new definition for rape in 1991, which removed the marital exemption, and also made the crime gender-neutral; before 1991 the legal definition of rape was a man forcing, by violence or threat of thereof, a woman to engage in sexual intercourse outside of marriage.


title: Marital rape

text: In Italy the law on rape, "violenza carnale" ('carnal violence', as it was termed) did not contain a statutory exemption, but was, as elsewhere, understood as inapplicable in the context of marriage. Although Italy has a reputation of a male dominated traditional society, it was quite early to accept that the rape law covers forced sex in marriage too: in 1976 in "Sentenza n. 12857 del 1976", the Supreme Court ruled that "the spouse who compels the other spouse to carnal knowledge by violence or threats commits the crime of carnal violence" (""commette il delitto di violenza carnale il coniuge che costringa con violenza o minaccia l’altro coniuge a congiunzione carnale"").


title: Marital rape

text: Cyprus criminalized marital rape in 1994. Marital rape was made illegal in North Macedonia in 1996. In Croatia marital rape was criminalized in 1998.


title: Marital rape

text: In 2006, Greece enacted "Law 3500/2006", entitled "For combating domestic violence", which punishes marital rape. It entered into force on 24 October 2006. This legislation also prohibits numerous other forms of violence within marriage and cohabiting relations, and various other forms of abuse of women.


title: Marital rape

text: Thailand outlawed marital rape in 2007. The new reforms were enacted amid strong controversy and were opposed by many. One opponent of the law was legal scholar Taweekiet Meenakanit who voiced his opposition to the legal reforms. He also opposed the making of rape a gender neutral offense. Meenakanit claimed that allowing a husband to file a rape charge against his wife is "abnormal logic" and that wives would refuse to divorce or put their husband in jail since many Thai wives are dependent on their husbands.


title: Marital rape

text: Section 375 of the Indian Penal Code (IPC) considers the forced sex in marriages as a crime only when the wife is below age 15. Thus, marital rape is not a criminal offense under the IPC. Marital rape victims have to take recourse to the Protection of Women from Domestic Violence Act 2005 (PWDVA). The PWDVA, which came into force in 2006, outlaws marital rape. However, it offers only a civil remedy for the offence. In February 2022, Smriti Irani (Minister for Women and Child Development) told parliament that “The Government of India has initiated the process for comprehensive amendments to criminal laws in consultation" in response to questions on marital rape, which assures some provisions will be made on criminalizing marital rape.


title: Marital rape

text: Recent countries to criminalize marital rape include Zimbabwe (2001), Turkey (2005), Cambodia (2005), Liberia (2006), Nepal (2006),


title: Marital rape

text: Mauritius (2007), Ghana (2007), Malaysia (2007), Thailand (2007), Rwanda (2009), Suriname (2009), Nicaragua (2012), Sierra Leone (2012), South Korea (2013), Bolivia (2013), Samoa (2013), Tonga (1999/2013). Human rights observers have criticized a variety of countries for failing to effectively prosecute marital rape once it has been criminalized. South Africa, which criminalized in 1993, saw its first conviction for marital rape in 2012.


title: Marital rape

text: The traditional definition of rape in the United States is the forced sexual intercourse by a male with a "female "not his wife"", making it clear that the statutes did not apply to married couples. The 1962 Model Penal Code repeated the marital rape exemption, stating:


title: Marital rape

text: Reforms of marital rape laws in the United States began in the mid-1970s with the criminalization of marital rape. The earlier laws of the 1970s often required the husband and wife to no longer be living together for marital rape charges to be brought. The case in the United States that first challenged this cohabitation clause was "Oregon v. Rideout" in 1978. Although the husband was acquitted of raping his wife, it spurred the movement towards reform. By 1993 marital rape was a crime in all 50 states. Still, in the 1990s, most states continued to differentiate between the way marital rape and non-marital rape was viewed and treated. The laws have continued to change and evolve, with most states reforming their laws in the 21st century. But there are still states, like South Carolina, where marital and non-marital rape are treated quite differently under the law.


title: Marital rape

text: In the 1990s, most states differentiated between the way marital rape and non-marital rape were treated. These differences were visible through shorter penalties, taking into account whether or not violence was used, and allowing for shorter reporting periods. (Bergen, 1996; Russell, 1990).


title: Marital rape

text: The laws have continued to change and evolve, with most states reforming their legislation in the 21st century, in order to bring marital rape laws in line with non-marital rape, but even today there remain differences in some states. With the removal, in 2005, of the requirement of a higher level of violence from the law of Tennessee, which now allows for marital rape in Tennessee to be treated like any other type of rape, South Carolina remains the only US state with a law requiring excessive force/violence (the force or violence used or threatened must be of a "high and aggravated nature").


title: Marital rape

text: In most states the criminalization has occurred by the removal of the exemptions from the general rape law by legislation, or by courts striking down such exemptions as unconstitutional. Some states have created a distinct crime of spousal rape. California, for example, has separate criminal offenses for rape (Article 261) and for spousal rape (Article 262).


title: Marital rape

text: Although the issue of marital rape was highlighted by feminists in the 19th century, and was also deplored by thinkers such as John Stuart Mill and Bertrand Russell (see above section 'Feminist critique in the 19th century'), it was not until the 1970s that this issue was raised at a political level. The late 1970s also saw the enactment of Sexual Offences (Amendment) Act of 1976, which provided the first statutory definition of rape (prior to this rape was defined by the common law). The Criminal Law Revision Committee in their 1984 Report on Sexual Offences rejected the idea that the offense of rape should be extended to marital relations; writing the following:


title: Marital rape

text: The committee also expressed more general views on domestic violence arguing that "Violence occurs in some marriages but the wives do not always wish the marital tie to be severed" and reiterated the point that domestic incidents without physical injury would generally be outside the scope of the law: "Some of us consider that the criminal law should keep out of marital relationships between cohabiting partners—especially the marriage bed—except where injury arises, when there are other offences which can be charged."


title: Marital rape

text: Five years later, in Scotland, the High Court of Justiciary took a different view, abolishing marital immunity, in "S. v. H.M. Advocate", 1989. The same happened in England and Wales in 1991, in "R v R" (see below). Very soon after this, in Australia, at the end of 1991, in "R v L", the High Court of Australia ruled the same, ruling that if the common law exemption had ever been part of the Australian law, it no longer was (by that time most Australian states and territories had already abolished their exemptions by statutory law).


title: Marital rape

text: The marital rape exemption was first referred to in 1736 in Matthew Hale's "History of the Pleas of the Crown" (see above). It was abolished in England and Wales in 1991 by the Appellate Committee of the House of Lords, in the case of "R v R", which was the first occasion where the marital rights exemption had been appealed as far as the House of Lords, and it followed the trio of cases since 1988 where the marital rights exemption was held to exist. The leading judgment, unanimously approved, was given by Lord Keith of Kinkel. He stated that the contortions being performed in the lower courts in order to avoid applying the marital rights exemption were indicative of the absurdity of the rule, and held, agreeing with earlier judgments in Scotland and in the Court of Appeal in "R v R", that “the fiction of implied consent has no useful purpose to serve today in the law of rape” and that the marital rights exemption was a “common law fiction” which had never been a true rule of English law. R's appeal was accordingly dismissed, and he was convicted of the rape of his wife.


title: Marital rape

text: The first attempted prosecution of a husband for the rape of his wife was "R v Clarke" (1949). Rather than try to argue directly against Hale's logic, the court held that consent in this instance had been revoked by an order of the court for non-cohabitation. It was the first of a number of cases in which the courts found reasons not to apply the exemption, notably "R v O’Brien" (1974) (the obtaining of decree nisi), "R v Steele" (1976) (an undertaking by the husband to the court not to molest the wife) and "R v Roberts" (1986) (the existence of a formal separation agreement).


title: Marital rape

text: There are at least four recorded instances of a husband successfully relying on the exemption in England and Wales. The first was "R v Miller" (1954), where it was held that the wife had not legally revoked her consent despite having presented a divorce petition. "R v Kowalski" (1988) was followed by "R v Sharples" (1990), and "R v J" (1991), a judgment made after the first instance decision of the Crown Court in "R v R" but before the decision of the House of Lords that was to abolish the exemption. In "Miller", "Kowalski" and "R v J" the husbands were instead convicted of assault. The "R v Kowalski" case involved, among other acts, an instance of non-consensual oral sex. For this, the husband was convicted of indecent assault, as the court ruled that his wife's "implied consent" by virtue of marriage extended only to vaginal intercourse, not to other acts such as fellatio. (At that time the offense of 'rape' dealt only with vaginal intercourse.) In "R v Sharples" (1990) it was alleged that the husband had raped his wife in 1989. Despite the fact that the wife had obtained a family protection order before the alleged rape, the judge refused to accept that rape could legally occur, concluding that the family protection order had not removed the wife's implied consent, ruling that: "it cannot be inferred that by obtaining the order in these terms the wife had withdrawn her consent to sexual intercourse".


title: Marital rape

text: By 1991, when the exemption was removed, the Law Commission in its "Working Paper" of 1990 was already supporting the abolition of the exemption, a view reiterated in their "Final Report" that was published in 1992; and international moves in this direction were by now common. Therefore, the result of the "R v R" case was welcomed. But, while the removal of the exemption itself was not controversial, the way through which this was done was; since the change was not made through usual statutory modification. The cases of "SW v UK" and "CR v UK" arose in response to "R v R"; in which the applicants (convicted of rape and attempted rape of the wives) appealed to the European Court of Human Rights arguing that their convictions were a retrospective application of the law in breach of Article 7 of the European Convention on Human Rights. They claimed that at the time of the rape there was a common law exemption in force, therefore their convictions were "post facto". Their case was not successful, with their arguments being rejected by the European Court of Human Rights, which ruled that the criminalization of marital rape had become a reasonably foreseeable development of the criminal law in the light of the evolution of social norms; and that the Article 7 does not prohibit the gradual judicial evolution of the interpretation of an offense, provided the result is consistent with the essence of the offense and that it could be reasonably foreseen.


title: Marital rape

text: A new definition of the offense of 'rape' was created in 1994 by the section 142 of the Criminal Justice and Public Order Act 1994, providing a broader definition that included anal sex; and an even broader definition was created by the Sexual Offences Act 2003, including oral sex. The law on rape does not—and did not ever since the removal of the marital exemption in 1991—provide for any different punishment based on the relation between parties. However, in 1993, in "R v W 1993 14 Cr App R (S) 256", the court ruled: "It should not be thought a different and lower scale automatically attaches to the rape of a wife by her husband. All will depend upon the circumstances of the case. Where the parties are cohabiting and the husband insisted upon intercourse against his wife's will but without violence or threats this may reduce sentence. Where the conduct is gross and involves threats or violence the relationship will be of little significance."


title: Marital rape

text: At the time of "R v R" (see "England and Wales" above), rape in Northern Ireland was a crime at common law. Northern Ireland common law is similar to that of England and Wales, and partially derives from the same sources; so any (alleged) exemption from its rape law was also removed by "R v R". In March 2000, a Belfast man was convicted for raping his wife, in the first case of its kind in Northern Ireland.


title: Marital rape

text: Until 28 July 2003, rape in Northern Ireland remained solely an offense at common law that could only be committed by a man against a woman only as vaginal intercourse. Between 28 July 2003 and 2 February 2009 rape was defined by the Criminal Justice (Northern Ireland) Order 2003 as "any act of non-consensual intercourse by a man with a person", but the common law offense continued to exist, and oral sex remained excluded. On 2 February 2009 the Sexual Offences (Northern Ireland) Order 2008 came into force, abolishing the common law offense of rape, and providing a definition of rape that is similar to that of the Sexual Offences Act 2003 of England and Wales. The Public Prosecution Service for Northern Ireland has the same policy for marital rape as for other forms of rape; it states in its "Policy for Prosecuting Cases of Rape" document that: "The Policy applies to all types of rape, including marital and relationship rape, acquaintance and stranger rape, both against male and female victims".


title: Marital rape

text: In Australia, the immunity for marital rape was removed in all states and territories, either by statute or judicial decision, between late 1970s and early 1990s. Previously, the exemption of marital rape was based on the English common law offense of rape, being generally understood as "carnal knowledge", "outside of marriage", of a female against her will. The common law definition of rape continued to apply in some states, while others codified the definition, which in each case included a marital exemption. In Queensland, for example, the provision read: "Any person who has carnal knowledge of a woman or girl, "not his wife", without her consent, or with her consent, if the consent is obtained by force, or by means of threats or intimidation of any kind, or by fear of bodily harm, or by means of false and fraudulent representations as to the nature of the act, or, in the case of a married woman, by personating her husband, is guilty of a crime, which is called rape."


title: Marital rape

text: The first Australian state to deal with marital rape was South Australia, under the progressive initiatives of Premier Don Dunstan, which in 1976 partially removed the exemption. Section 73 of the "Criminal Law Consolidation Act Amendment Act 1976" (SA) read: "No person shall, by reason only of the fact that he is married to some other person, be presumed to have consented to sexual intercourse with that other person". Nevertheless, the laws did not go as far as equating marital with non-marital rape; the law required violence or other aggravating circumstances, in order for an act of marital intercourse to be rape.


title: Marital rape

text: The first Australian jurisdiction to completely remove the marital exemption was New South Wales in 1981. Western Australia, Victoria, and ACT did the same in 1985; and Tasmania in 1987. Discussions of criminalization of marital rape were already taking place in Queensland in the late 1970s, but it was not until 1989 that the exemption was removed and the Northern Territory did the same in 1994. In 1991, in "R v L", the High Court of Australia ruled that "if it was ever the common law that by marriage a wife gave irrevocable consent to sexual intercourse by her husband, it is no longer the common law." The case led to South Australia changing its law in 1992.


title: Marital rape

text: In India there are no law provisions related to the marital rape and are being demanded by the commission to enact laws to bring it in the criminal jurisdiction.


title: Marital rape

text: In a variety of cultures, marriage after a rape of an unmarried woman has been treated historically as a "resolution" to the rape, that is, a "reparatory marriage". In some countries, the mere offer to marry the person one has raped is sufficient to exonerate the perpetrator from criminal prosecution. Although laws that exonerate the perpetrator if he marries his victim after the rape are often associated with the Middle East, such laws were very common around the world until the second half of the 20th century. For instance, as late as 1997, 14 Latin American countries had such laws, although most of these countries have now abolished them.


title: Marital rape

text: Whether women were forced to marry their rapist, or the marriage was concluded before the violence began, many victims remain in chronically violent relationships. While there are many reasons for which victims of marital rape remain in their marriages, one important reason is that divorce may be hard to obtain and/or is stigmatized (Kwiatowski, 70). Cross-culturally, one of the barriers that keep victims within their marriages is the shame and guilt they feel surrounding marital rape (Bergen, 2016), or general taboos around sexuality(Kwiatkowski, 2016) (Torres, 2016). Lastly, some victims do not categorize their abuse as marital rape in order to minimize the violence they endure. This is used as a defense mechanism so they can continue to endure their abuse (Menjívar, 2016).


title: Marital rape

text: Forced marriage and child marriage are prevalent in many parts of the world, especially in parts of Asia and Africa. A forced marriage is a marriage where one or both participants are married without their freely given consent; while a child marriage is a marriage where one or both parties are younger than 18. These types of marriages are associated with a higher rate of domestic violence, including marital rape. These forms of marriage are most common in traditional societies which have no laws against sexual violence in marriage, and where it is also very difficult to leave a marriage. Incidents taking place in some of these countries (such as Yemen) have received international attention. The World Health Organization states, under the rubric "Customary forms of sexual violence", (pp. 156):


title: Marital rape

text: One type of forced marriages occurs in Guatemala (called robadas) and Mexico (called rapto). Robadas refers to "…abductions, in which women are ‘taken’ during the period of courtship, sometimes semivoluntarily but other times by force, by a suitor who wants to start a marital relationship with them" (Menjívar, 2016). Rapto refers to "…an abduction for sexual or erotic purposes or marriage" (Bovarnik, 2007). Following the abduction, marriage is often encouraged to maintain the family honor (Bovarnik, 2007).


title: Marital rape

text: In these types of forced marriages, the marital union begins with the man's intense sense of control over the woman, combined with the understanding that the wife is the possession of her husband (Menjívar, 2016). This foundation of marriage had direct implications for sexual violence within the marriage. In reference to the practice of robadas, Cecilia Menjívar (2016) writes, "…unions that start out from the violent act of a robada can continue to breed violence, abuse, and mistreatment in the union." In addition, women victims of robadas often face embarrassment and blame, despite the act usually being initiated by male perpetrators (Menjívar, 2016). Women are blamed for disobeying their parents or not resisting their abductor strong enough (Menjívar, 2016). This notion of blaming the woman also occurs in reference to rapto in rural Mexico. Silvie Bovarnik (2007) writes, "In many cases, men and women alike look for the fault of responsibility in women's behavior due to traditional conceptualisations of women as ‘pillars of honour.’" Abduction and rape compromises a woman's moral integrity, and therefore her honor (Bovarnik, 2007). Many of these women, who were given little choice in their marriage, are left to live with their abusers.


title: Marital rape

text: The prevalence of marital rape is difficult to assess, especially outside the Western World. Discussing sexual matters in many cultures is taboo. One problem with studies on marital rape is that the Western concept of consent is not understood in many parts of the world. Because many societies operate on social norms which create a dual system of sexual morality—one for sexual intercourse that is "marital" which is seen as an obligation that cannot be refused, and "extra-marital", which is seen as wrong (or illicit/illegal). Issues of consent are poorly understood, especially by young wives (which are often young girls who do not have a proper understanding of sexual rights). For instance in an interview in a study for the World Health Organization, a woman from Bangladesh who described being hit by her husband and forced to have sex said that: ""I thought this is only natural. This is the way a husband behaves"." Research has, nevertheless, associated specific regions with a very high level of violence, including sexual violence, against women by husbands/partners. An example of such a place is Ethiopia.


title: Marital rape

text: The prevalence of marital rape depends on the particularly legal, national, and cultural context. In 1999, the World Health Organization conducted a study on violence against women in Tajikistan, surveying 900 women above the age of 14 in three districts of the country and found that 47% of married women reported having been forced to have sex by their husband. In Turkey 35.6% of women have experienced marital rape sometimes and 16.3% often.


title: Marital rape

text: The earliest study in the Western World attempting to survey marital rape was an unpublished study by Joan Seites in the spring of 1975. Seites sent questionnaires to 40 rape-crisis centers from a list compiled by the Center for Women Policy Studies (Washington, DC). 16 Centers completed questionnaire for a response rate of 40%. Of the 3,709 reported calls dealing with rape and attempted rape received by the 16 centers, 12 calls dealt with marital rape (0.3%). Because rape-crisis centers did not always record the relationships of the callers, whether the 12 reported calls fully represent the number of married relationships cannot be certainly known.


title: Marital rape

text: In 1982 Diana E. H. Russell, a feminist writer and activist, conducted the seminal study on marital rape. Her study surveyed a total of 930 women from San Francisco, California (50% non-response rate, non-English speaking Asian women were specifically excluded as non-reliable respondents), of whom 644 were married, divorced, or who self-identified as having a husband although not married. Six of these women (1%) self-assessed that they had been raped by their husbands, ex-husband, or de facto husbands. The survey interviewers, however, classified 74 (12%) of these women as having been raped. Of the 286 non-married women in the sample, 228 (80%) were classified by the survey interviewers as having been raped. Russell found that when repeated instances of rape as classified by the survey interviewers, by husbands or ex-husbands, over the entire course of the marriage are included, these account for 38% of all rape instances, in comparison to the remaining 62% occurring in non-marital instances.


title: Marital rape

text: David Finkelhor and Kersti Yllo published a study in 1985 on marital rape that drew on a scientifically selected area probability sample from the metropolitan Boston area of 323 women who were either married or previously married who had a child living with them between the ages of six and fourteen. The study found that of the women who were married the instance of sexual relations through physical force or the threat thereof was 3%.


title: Marital rape

text: In 1994, Patricia Easteal, then Senior Criminologist at the Australian Institute of Criminology, published the results of survey on sexual assault in many settings. The respondents had all been victims of numerous forms of sexual assault. Of the victim sub-sample, 10.4% had been raped by husbands or husbands, with a further 2.3% raped by estranged husbands/"de factos".


title: Marital rape

text: In 2002 Basile published research intended to address the lack of a nationally probability sample to-date that measured intimate sexual coercion faced by married women. Data were collected in a 1997 national poll by a random telephone survey of 1,108 residents in the continental U.S. of persons 18 years old or older. The survey had a 50% response rate. Of the 1,108 respondents, the 506 men were excluded from any inquiry into unwanted sexual experiences, leaving 602 (54%) women respondents for the study. 398 (66%) women indicated no unwanted sexual relations (their marital status is not given), and 204 (34%) women responded as having engaged in unwanted sex after being subject to some level of sexual coercion; types of sexual coercion included receiving ‘a gift’, ‘ a nice dinner’, ‘a back rub’, ‘kissing’, etc. through threatened harm and physical coercion. Of this group, a sub-sample of 120 (59%) were married, of which 9% responded as having been subject to physical force.


title: Marital rape

text: Rape by a spouse, partner or ex-partner is more often associated with physical violence. A nine-nation study within the European Union found that current or ex-partners were the perpetrators of around 25% of all sexual assaults, and that violence was more common in assaults by ex-partners (50% of the time) and partners (40%) than in assaults by strangers or recent acquaintances (25%).


title: Marital rape

text: Attributing the effects of marital rape in research is problematic as it is nearly impossible to find a large enough sample of spouses to study who have experienced sexual violence but have not also been physically assaulted by their spouse. Marital rape can spread sexually transmitted diseases and HIV, adversely affecting a victim's physical and psychological health. In sub-Saharan countries with very high prevalence rates of HIV, such as Lesotho, instances of multiple partnerships and marital rape exacerbate the spread of HIV.