• Play Title: Gross Indecency: The Three Trials of Oscar Wilde
• Author: Moisés Kaufman
• First performed:  1997
• Page count: 83

Summary

In early April of 1895, Oscar Wilde took a libel case against Lord Sholto Douglas. At the time, Wilde had been in a longstanding ‘friendship’ with Douglas’s son, Bosie. An offensive note had been left at Wilde’s club by the disgruntled father, which led to the libel action. By late May, Wilde was unexpectedly beginning a two-year prison sentence for acts of gross indecency. Two years of hard labour served at various jails, namely Newgate, Pentonville, Wandsworth and Reading Gaol. Moisés Kaufman’s play provides an overview of this strange course of events that led a celebrated playwright to such infamy and ruin. The work is a mélange of court records, newspaper reports, Wilde’s writings, personal letters, and autobiographical excerpts. Breaking with the unity of time familiar in drama, Kaufman uses material that predates and postdates the numerous legal trials. As a result, the play may be seen as a retrospective view of the true cause of Wilde’s downfall. The core themes of the work include artistry, love, law, and revenge.

Ways to access the text: listening/reading/watching

It is easy to find an online source for this play. For example, it’s available via the Internet Archive and on Scribd (pdf).
There is a 1960 movie entitled The Trials of Oscar Wilde, which covers the same court proceedings, but it’s not the same as Kaufman’s version.
For those interested in a discussion about Wilde’s sex scandal and subsequent trials, please check out The Rest is History podcast (episodes 341 and 342).
I would recommend listening to an audiobook version of the play because this works far better for courtroom dialogues. Everand carries an audiobook version.

Why listen to/read Gross Indecency?

Kaufman’s play touches on several conundrums in Wilde’s life. First and foremost, why does a flamboyant man, who takes young, male lovers, ever risk taking a libel case where he needs to prove that he is not participating in homosexual acts? This leads one to consider Wilde’s love for Lord Alfred Douglas (Bosie) and how it seemingly blinded a highly intelligent man to the harsh realities of the English justice system. Bosie had encouraged the case as a means of avenging his father. Beyond these core topics, the play also considers the idea of a gay identity in 1890s England. Remember, the law punished the act of sodomy, rather than a fixed, recognisable identity. Furthermore, the play looks at the problem of famous people on trial and how political intrigue influences justice.

Post-reading discussion/interpretation

_{A History of Libel: Wilde, Liberace, and Vidal}

Kaufman opens his play with an arresting quote from Wilde’s De Profundis – “The past, present and future are but one moment in the sight of God” (13). The play reflects this stance by providing details of Wilde’s trial, plus prior and much later events for a panoramic, historical context. Taking Wilde’s lead – one should not cower in fear of one’s past. Guilt and shame should not be the preoccupations of anyone, especially not an artist. However, the various reference materials chosen by Kaufman to create the play, from love letters to newspaper headlines, still form the impression of an inevitable, tragic outcome for Mr Wilde. The silver-tongued, Irish playwright had tremendous successes but will always be associated with a humiliating downfall. Yet there are obvious problems with this synopsis. In her review of Kaufman’s play, Sandra F. Siegel wrote the following.

“The tragic life that … Kaufman dramatises, of a man driven by impulses within himself and beyond his control, impulses that drive him to self-destruction, has been the presupposition of Wilde criticism since the turn of the century.” (Siegel 35)

Wilde is seen as an eternally tragic figure and any rearrangement of the details of his life does not free him of this apparently fixed label. Maybe his failure nourishes a perverse interest. William Cohen asserts that “In spite of the frequency with which it has been told, the story of Oscar Wilde’s downfall one hundred years ago has lost none of its capacity to shock, amaze, and distress audiences” (529). Indeed, there was a spate of new plays about Oscar Wilde around the 100th anniversary of his death: Saint Oscar (’89) by Terry Eagleton, The Judas Kiss (’98) by David Hare, The Invention of Love (’98) by Tom Stoppard, and In Extremis (’00) by Neil Bartlett. As Peter Dickinson writes, “Oscar Wilde has, of course, repeatedly been subjected to posthumous conscription by scholars, critics, writers, and artists as the exemplary literary, sexual, and national outlaw” (416). In effect, Wilde’s story serves to answer anachronistic questions. In defence of Kaufman’s particular approach, he aims to show “how theatre can reconstruct history, not as a seamless and unified record of events, but as an amalgam of diverse and conflicting accounts” (Dickinson 422). Nonetheless, the murmured dissent that emanates from the various documents does not considerably change one’s view of Wilde’s downfall.

This essay will look specifically at Wilde’s decision to take the fateful libel case against Lord Queensberry. Instead of a man blinded by love or pride, Wilde emerges as a very public artist who desperately needed to retain his audience’s loyalty. Wilde took a risky decision; he lost, but he could just as well have won. One sees Wilde’s example repeated in some extraordinary libel cases of the 20th century. This is not to say that Wilde set a precedent. In fact, had other gay men paid attention to Wilde’s fate, they would never have dared to press libel charges. However, they felt they had to, and that is the crux of the argument outlined in this essay.

The title of Kaufman’s play refers to three successive court cases involving Oscar Wilde. The first was the playwright’s libel case against Lord Sholto Douglas, which began on the 3rd of April 1895. Due to upcoming, embarrassing testimony involving several male prostitutes, Wilde was quickly convinced to drop the case. In the two following trials, Wilde was the defendant. His displays of bravado and flippancy in the first trial were now being sorely repaid. Too much information had inadvertently been made public. He faced criminal charges of homosexual conduct with men. The jury in the first of these follow-up cases was unable to reach a verdict, but the retrial jury found Wilde guilty of gross indecency. His fate was sealed.

The play contains an intriguing discussion around Wilde’s court testimony. However, it proves to be an elaborate distraction. Kaufman quotes the opinions of Professor Marvin Taylor and George Bernard Shaw, who was Wilde’s contemporary and friend. In Taylor’s opinion, the main charge against Wilde was not sodomy but rather “his subversive beliefs about art, about morality … about Victorian society” (Kaufman 49). Regarding Wilde’s refusal to identify as a homosexual, Taylor asserts that such an identity did not truly exist in Victorian times: homosexuality was seen chiefly as an act. The modern concept of a homosexual identity was not yet socially established. According to Talyor, Wilde was intent on using the court as a forum to expound his intellectual ideas about beauty and art. And, yes, Taylor eventually admits that Wilde told lies to the court by denying any sexual relations with men. Shaw’s defence of Wilde’s actions is far more robust; if Wilde believed that homosexual acts were not morally wrong then he was entitled to plead not guilty. Here one sees a schism emerge between Wilde’s personal sense of morality and the court’s, which is quite unorthodox. Beyond Taylor’s misdirection and mild evasion and Shaw’s semantic gymnastics, there is still one crucial, underlying reason for Wilde’s lies. To be branded a sodomite was a slur from which nobody could recover in 1890’s England. This concurs with Shaw’s plain-spoken view that ‘not guilty’ (54) was really the only viable plea.

Sir Edward Clarke, Wilde’s lawyer, refers to sodomy as “the gravest of all offences” (Kaufman 15). For historical context, convictions for sodomy carried a penalty of death in England up until 1861, which was then changed to life imprisonment from 1861 onwards (Adut 215). In 1885, the Labouchere Amendment “made all homosexual acts of ‘gross indecency’ illegal” (UK Parliament). Thus, sodomy was no longer the only punishable crime; any intimate interaction between two men was now open to prosecution. Prosecutors suddenly had a much easier task in establishing the burden of proof. The new law was soon nicknamed the Blackmailer’s Charter since it exposed gay men to extortion. In conjunction with harsh laws, public opinion was also quite unsympathetic, as Ari Adut explains.

“The Victorians held homosexuality in horror, and Britain stood out at the turn of the 20th century as the only country in Western Europe that criminalized all male homosexual acts with draconian penalties.” (Adut 214)

The stigma attached to homosexual acts is something that Kaufman’s play does not sufficiently address. Quotations from Professor Taylor and George Bernard Shaw obstruct one’s view of a substantial issue: public shaming. At Wilde’s final trial, the judge gave him the maximum sentence, saying, “People who do these things are dead to all sense of shame, and one cannot hope to produce any effect upon them” (Kaufman 79). Wilde had committed acts that were unspeakable and actually unprintable in national newspapers at the time. Therefore, he would be ostracised from respectable society forever. Contrary to the judge’s assertion, Wilde understood public shame all too well. His father Sir William Wilde, a renowned Dublin surgeon, was accused of rape by Mary Travers years earlier. Oscar was just a child at the time. Travers claimed William Wilde had raped her while she was anesthetised with chloroform. Oscar’s mother, Jane, subsequently wrote a libellous letter to Travers’ father and the whole affair ended up in a Dublin courtroom in 1864 (Walshe). The Wildes, a prominent Dublin family, somehow maintained public favour, but the case had threatened to ruin them. It is possible that Oscar was emboldened by this early experience. William Wilde was likely guilty of rape, but faced with a courtroom battle, the Wildes tackled it head-on. Unlike his father, Oscar’s ‘victims’ were consenting males whom he wined, dined, bedded, and subsequently showered with gifts. Guilty of no moral crime, at least in his own view, Oscar was willing to fight anyone who threatened to ruin his reputation and career. The situation is certainly paradoxical because Wilde was uninhibited about his sexual relations with men, yet he was unwilling to accept the inevitable social opprobrium and legal censures that went hand in hand with such behaviour in Victorian England. Like Shaw, he had evidently constructed a highly refined argument in his own mind. Kaufman’s contextualization of this argument leads one to lose sight of the core issue of shame and its potential to destroy a man and a reputation.

In Gross Indecency, one witnesses Mr Wilde lost in lofty arguments about Shakespeare. At other moments, he is a love fool obsessing about what will please Bosie. In order to unseat these fixed perspectives on Wilde, while keeping a focus on the trial, one needs to compare him with other gay men who faced the same or similar legal predicaments. This pseudo-challenge throws up the most unlikely yet also most apt name – Liberace. Initially trained as a classical pianist, Liberace went on to be one of America’s most popular entertainers. With a successful TV show in the 1950s, bestselling records, concert tours abroad, and a decades-long residency in Las Vegas, Liberace was one of the highest-paid performers of his era. He was also a closet homosexual. Devoted to his audience, he worked hard to maintain a pristine public persona that would ensure the ongoing loyalty of that same audience. Liberace went to court twice in the late 1950s in connection with libel actions. In 1957, Liberace along with actress Maureen O’Hara testified against Confidential magazine regarding libelous stories. The magazine had printed an innuendo-laden story about the pianist entitled “Why Liberace’s theme song should be “Mad About The Boy!” A British newspaper called the Daily Mirror had also printed an article in 1956 referencing Liberace’s homosexuality. After some scheduling delays, he took a libel case against the newspaper in 1959, in London. Like Oscar Wilde, Liberace denied his homosexuality in all legal proceedings.

Slander is defined as an untruth that results in reputational damage. In circumstances where slander occurs, the victims may take a libel case to correct the public record and claim compensation. Władziu Valentino Liberace (his full name) and Oscar Wilde chose to do just that. The specific slander directed toward both men is that they are accused of acting like homosexuals. It is noteworthy that little had changed between 1895 and 1959 regarding the ostracised status of gay men in Britain. However, many people are still bemused by the apparent hypocrisy of these men since both were indeed gay. Thus, the egregious lie essential for a proper definition of slander is missing, which leaves just the reputational damage as the main consideration. The respective legal actions set out to fix a single issue. In short, the men had suffered insults that risked ending their public careers. The court cases were self-evidently never about the truth, they were solely about artistic survival.

There is an uncanny resemblance between the slanders directed at Wilde and Liberace. In neither case were the men openly accused of participating in sodomy. Instead, they were essentially called gay posers. In Wilde’s case, the Marquess of Queensberry left a card at his club which named him as a “posing somdomite” (Kaufman 14). Sir Edward Clarke, Wilde’s lawyer, sets out the fine detail of the accusation, as follows.

“The words of the libel are not directly an accusation of the gravest of all offenses [sodomy] – the suggestion is that there was no guilt of the actual offense, but that in some way or other the person of whom those cards were written did appear, nay, desired to appear – and pose to be a person guilty of or inclined to the commission of the gravest of all offenses.” (Kaufman 15)

A carefully defined point is diligently outlined by Clarke in this impressive piece of 19th-century legalese. Although it ostensibly outlines Lord Douglas’s charge against Wilde, the description also helps to ‘construct’ a type of man who typically commits such acts – the birth of the modern homosexual. Now move the calendar forward to September 1956 when the Daily Mirror, London, printed an innuendo-laden description of Liberace. The modern text is a more flamboyant, wordier piece than Lord Douglas’s misspelt taunt. Written by newspaper columnist William Connor, the offending description of Liberace is as follows.

“The summit of sex – the pinnacle of masculine, feminine, and neuter. Everything that he, she, and it can ever want… a deadly, winking, sniggering, snuggling, chromium-plated, scent-impregnated, luminous, quivering, giggling, fruit-flavoured, mincing, ice-covered heap of mother love.” (Connor)

The trigger word is ‘fruit’ since this was widely acknowledged American slang for a homosexual. In each case, Liberace’s and Wilde’s, the offence was caused by the suggestion that they were posing as homosexuals. Naturally, the underlying insinuation is that if someone looks it then they probably are it, namely gay. Homosexual acts were still illegal in Britain and the USA in the 1950s, just as they had been in the 1890s. Therefore, few insults could be as damaging as the ones used by Lord Queensberry and the columnist Mr Connor. Gay men were still viewed as social untouchables.

Liberace and Wilde lied in their respective court cases by making outright denials of their sexual preferences. Holding steadfastly to a lie was a high-risk strategy, but one that could potentially pay off. Wilde knew that Queensberry meant to ruin him. Queensberry had inferred that Wilde was a homosexual in a cautionary letter to his son in April 1894. He threatened to make a public scandal if the men’s romantic affair did not end. Queensberry then called to Wilde’s family home in June 1894 regarding the same issue, and he subsequently tried to disrupt the opening night of The Importance of Being Earnest in February 1895. In short, Queensberry posed a substantial, ongoing threat to Wilde’s public reputation and financial livelihood. True to Wilde’s greatest fears, when he was eventually unmasked as a homosexual due to the court case, he was reduced to penury within mere days. His two successful West End plays immediately closed resulting in an income freeze. At the same time, he owed huge legal fees and had every old creditor descend upon him at once. In stark contrast, Liberace won his libel case in London in 1959 – “He was awarded a then-record £8,000 in damages (about £500,000 in today’s money)” (Greenslade). In the previous American debacle with Confidential magazine, forty thousand dollars in damages had been awarded to Liberace in an out-of-court settlement (Gabler). Liberace had repeatedly won, but more importantly, he had issued a stark warning to any potential, future slanderer. Not until Liberace’s former lover sued the maestro for palimony in 1982 did he have to face the same accusation of homosexuality (which he denied, again). William Povletich explains that “during an era when the American public would have responded to his homosexuality with hostility, rejection, and ill will, he [Liberace] was forced to live behind the illusion of sexual ambiguity” (15). Mr Connor of the Daily Mirror had taken direct aim at Liberace’s public persona in order to obliterate it. For stars like Liberace, the solution was to create a strict division between the public façade and the private truth – a division necessitated by a conservative era.

Many contradictions, even absurdities, surround the respective cases. For instance, Oscar Wilde married Constance Lloyd in 1884 and they had two sons. The Wildes were still married at the time of the various legal trials. In a more cynical vein, Liberace had gotten engaged to actress Joanne Rio in 1954, although the two never actually got married. Thus, the men had given the public impression of being heterosexual, which made accusations of homosexual conduct much more difficult to prove in legal cases. On the other hand, Ari Adut writes that by the end of the 1880s, “Wilde was already going around in public with a green carnation boutonniere—the badge of French homosexuals” (227). Of a more compromising nature was the fact that “Wilde’s homosexuality was well known long before his trials. His effeminate public persona fit fully the Victorian stereotype of the homosexual” (227). Liberace was also seen as quite effeminate and an exponent of high camp, which led to endless rumours about his sexuality. For instance, the offending Confidential magazine article described his arrival at Akron, Ohio, as follows – “Liberace, resplendent in a frilly white lace shirt with red polka dots, minced down the ramp from the plane” (Streete 18). When these men went to court to quell sexual innuendos and slanders, their respective levels of fame ensured massive publicity. The contrasting outcomes of their cases are difficult to explain. One crucial difference is that Wilde’s case threatened to tarnish the reputations of prominent English public figures. For example, Archibald Primrose, the British Prime Minister, was reputed to be a homosexual and he had had a close friendship with Lord Sholto Douglas’s other son, Francis, who later died in a shooting accident. The prime minister’s name came up during evidence in the case. Adut argues that “The vortex of the scandal, tarnishing more and more prominent names, forced the hands of the authorities to convict Wilde” (237). Liberace’s sexual dalliances posed no such threat. The situation appeared to have changed, however, when Liberace died in 1987. Raymond Carrillo, the Riverside County Coroner, rejected the death certificate signed by Liberace’s personal physician and ordered the body to be returned from Los Angeles for an autopsy (Sahagun and Nelson). Apparently, it was a public health issue. The autopsy result showed that the entertainer had died of an AIDS-related complication. The pristine, asexual reputation that Liberace had painstakingly maintained for a lifetime in the public eye had been deconstructed by a single press release. Like Wilde, Liberace was now being shamed publicly.

There is one other public, literary figure who bears a resemblance to Wilde, and that is Gore Vidal. In 1948, Vidal published his first novel called The City and the Pillar. A controversial book about a young gay man coming to terms with his sexuality, it is comparable to Wilde’s The Picture of Dorian Gray in both its themes and scandalous reception. Vidal’s own first love was a young man called James Trimble who later died at the Battle of Iwo Jima in 1945. Incidentally, The City and the Pillar is dedicated to Trimble. Vidal had many male partners in his life, but he never came out as gay since he believed that everyone is bisexual to some degree. Like Wilde and Liberace, Vidal’s sexuality was somewhat of an open secret. However, in the late 1960s, his private life became public very suddenly.

“On 28th August 1968 at a heated moment in a live TV debate the right-wing pundit William F. Buckley, Jr. called the celebrity writer and occasional political candidate Gore Vidal a “queer.” (Davidson 147)

Guy Davidson explains why the debate had become so heated – “Enraged at being labeled a pro- or crypto-Nazi, Buckley had reached for the epithet “queer” in order to publicly shame Vidal” (153). Fearing a libel case from Vidal, the TV station quickly sought legal advice and was assured that it would be a difficult case for Vidal to win (152). Vidal took no action, so all fears were soon allayed. Alas, the issue did not end there. Buckley approached Esquire magazine to write an article about the whole incident, to which they agreed. Vidal was also given a right of reply. Buckley, who had hoped to humiliate Vidal by using a homophobic slur, went on to defend his derogatory comment in an argument not dissimilar to the argument used against Wilde in court so many years previously. On that occasion, Wilde’s lawyer outlined the charge.

“That Mr Wilde published or caused to have published a certain immoral and indecent book with the title The Picture of Dorian Gray. The Marquess alleges that this book describes the relations, intimacies, and passions of certain persons guilty of unnatural practices.” (Kaufman 26).

Wilde’s art was seen as a means of attacking his personal character and suggesting that he was of the same ilk as the apparently homosexual personages in the novel. Buckley’s argument is almost identical since he sought “to show that through publicizing homosexuality in his writing, Vidal has forfeited his right to privacy” (Davidson 155). There follows a quote from Buckley’s article.

“The man [Gore Vidal] who in his essays proclaims the normalcy of his affliction, and in his art the desirability of it, is not to be confused with the man who bears his sorrows quietly. The addict is to be pitied and even respected, not the pusher” (Davidson 155)

By comparing the cases, one makes interesting insights. For one, Vidal was not willing to pursue a libel case as this would have required that he deny his sexual preferences. He dared not tread the same route as Wilde and Liberace. The Stonewall riots would take place in 1969, so, for historical context, this televised feud and the subsequent competing Esquire articles occurred well before gay liberation. In fact, Vidal took the gay slur directed at him and unexpectedly weaponized it against Buckley. In Vidal’s response article to Buckley’s, he refers to first meeting Buckley in the early 1960s and dismissing him as a “Right Wing Liberace” (Davidson 156). As Davidson points out, “Vidal relies on stereotypical, damning associations of homosexuality with effeminacy and flamboyance” (156). One could call this internalized homophobia on Vidal’s side, but he simply understood the toxic nature of the word ‘queer’ in late 1960s America. Also of note is Buckley’s comparison of Vidal with a drug pusher, except he was promoting a gay lifestyle. This is the same charge that Wilde faced – an older, influential, rich man who had a sexually corrupting influence over younger, less educated, impressionable men. 73 years separate these two stories, yet it’s as though nothing changed societally.

Wilde, Liberace, and Vidal were all men who perfectly understood their audiences. Orators, artists, wordsmiths, entertainers – they all understand the importance of keeping the public on their side. None of these men ever came out as gay in public despite the fact that each of them had long-term male lovers. As such, they are extremely disappointing role models for gay liberation. Of course, one needs to stop manipulating the stories of historical figures to fit a modern agenda since it always fails. Kaufman offers up conflicting perspectives on Wilde and the play benefits from this mild dissonance. Better still is the possibility for us to understand that none of these men would have had any social or artistic clout if they had been successfully branded as ‘queers’ in their own time. There are two stereotypes of artists – the hungry poet in the cold garret and the acclaimed figure who rides a high tide of success. One cannot be successful if one is ostracised from mainstream society. Wilde’s name should be accepted for the bankable commodity it really was. A romanticized view of Wilde solely as a queer trailblazer is to deny that he also needed to sell playhouse tickets to pay for luxurious dinners, chilled champagne, and good-looking young men. His name was also on the cover of a famous novel along with a book of children’s stories and countless essays. A tarnished, shameful name sells no books. Kaufman’s play exposes a survivor, moreover, a pragmatist. Lord Sholto Douglas was intent on ruining Wilde and the first libel case was Wilde’s valiant attempt to neutralize that threat. If all time appears as one moment to God, then maybe we should look at Wilde’s defining moment as his fight to survive, like his mother’s earlier fight in 1864 to protect the Wilde family name. This perspective is more refreshing and probably more truthful than the sad tale of his downfall caused by a selfish lover named Bosie.

Works Cited

Adut, Ari. “A Theory of Scandal: Victorians, Homosexuality, and the Fall of Oscar Wilde.” American Journal of Sociology, vol. 111, no. 1, 2005, pp. 213–48. JSTOR, https://doi.org/10.1086/428816.  

Cohen, William A. Theatre Journal, vol. 49, no. 4, 1997, pp. 529–31. JSTOR, http://www.jstor.org/stable/3208404. 

DAVIDSON, GUY. “Embarrassment in 1968: Gore Vidal’s Sexuality in the Public Sphere.” Mosaic: An Interdisciplinary Critical Journal, vol. 48, no. 1, 2015, pp. 147–64. JSTOR, http://www.jstor.org/stable/44030740. 

DICKINSON, PETER. “OSCAR WILDE: READING THE LIFE AFTER THE LIFE.” Biography, vol. 28, no. 3, 2005, pp. 414–32. JSTOR, http://www.jstor.org/stable/23540543. 

Gabler, Neal. “Confidential’s Reign Of Terror.” Vanity Fair, 1 April 2003, http://www.vanityfair.com/hollywood/2003/04/robert-harrison-confidential-magazine. 

Kaufman, Moisés. Gross Indecency: The Three Trials of Oscar Wilde. Dramatists Play Service Inc., 1999.  

Greenslade, Roy. “The meaning of ‘fruit’: how the Daily Mirror libelled Liberace.” The Guardian, 26 May 2009. http://www.theguardian.com/media/greenslade/2009/may/26/daily-mirror-medialaw 

Povletich, William. “Liberace: The Milwaukee Maestro.” The Wisconsin Magazine of History, vol. 92, no. 2, 2008, pp. 14–27. JSTOR, http://www.jstor.org/stable/25482105. 

Sahagun, Louis and Harry Nelson. “Cause of Death, AIDS at Issue: Liberace Autopsy Ordered by Coroner in Riverside County.” Los Angeles Times, 7 Feb 1987, http://www.latimes.com/archives/la-xpm-1987-02-07-me-1785-story.html. 

Siegel, Sandra F. “‘GROSS INDECENCY – THE THREE TRIALS OF OSCAR WILDE’: A Review of Moisés Kaufman’s Play.” The Wildean, no. 12, 1998, pp. 34–38. JSTOR, http://www.jstor.org/stable/45270300.  

Streete, Horton. “Why Liberace’s theme song should be ..“Mad About The Boy.”’ Confidential, 8 May 1957.  

Walshe, Eibhear. “The other Wilde trial: the Mary Travers libel case.” The Irish Times, 6 Dec 2014, http://www.irishtimes.com/culture/books/the-other-wilde-trial-the-mary-travers-libel-case-1.2027446 

“1885 Labouchere Amendment.” UK Parliament, http://www.parliament.uk/about/living-heritage/transformingsociety/private-lives/relationships/collections1/sexual-offences-act-1967/1885-labouchere-amendment.