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DPP v Bull [1995] QB 88 Divisional Court of the Queen's Bench Division

A man was charged with an offence under s.1(1) of the Street Offences Act 1959 which makes it an offence for a 'common prostitute to loiter or solicit in a public street or public place for the purposes of prostitution'. The magistrates found him not guilty on the grounds that 'common prostitute' only related to females and not males. The prosecution appealed by way of case stated.

The court held that the Act did only apply to females. The word prostitute was ambiguous and they applied the mischief rule. The Street Offences Act was introduced as a result of the work of the Wolfenden Report into homosexuality and prostitution. The Report only referred to female prostitution and did not mention male prostitutes. The QBD therefore held the mischief the Act was aimed at was controlling the behaviour of only female prostitutes.
Back to lecture outline on the mischief rule of statutory interpretation