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In 1997, the European Court of Human Rights case of Sutherland v United Kingdom held that a bigger age of consent for homosexuals than for heterosexuals was a breach of Article 14 in conjunction with Article 8 of the conference. The modify was a end result of the judgement in the European Court of Human Rights situation of Dudgeon v United Kingdom (1981) in which the ECHR held that a prohibition on homosexual acts was a breach of Article eight of the conference. As the Scottish Parliament experienced been set up prior to the reintroduction of the Bill, and the pertinent legislation was a devolved situation, the consent of that Parliament beneath the Sewel Convention was essential - had that consent not been granted, the Scottish provisions would have experienced to be taken out and it would not have been achievable to use the Parliament Act. The gender-neutral Crimes Bill 2011 passed the Gibraltar Parliament and got assented - employing the 2011 Supreme Court of Gibraltar selection and by repealing and updating 140-calendar year-outdated prison legislation of Gibraltar. Then in 2011, the gender-neutral Crimes Act 2011 carried out an equal and gender-neutral age of consent of sixteen and legalised anal sex for heterosexuals - reflecting the Supreme Court of Gibraltar's choice and by repealing and updating 140-year-aged legal regulations of Gibraltar

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