Canada (Attorney General) v. Bedford, 2012 ONCA ... - York University

Page: 44known to others, or monitored in some way, safety canbe increased;f. The use of drivers, receptionists and bodyguardscan increase safety; andg. Indoor safeguards including closed-circuit televisionmonitoring, call buttons, audio room monitoring, [and]financial negotiations done in advance can increasesafety.3. The bawdy-house provisions can place prostitutesin danger by preventing them from working in-call in aregular indoor location and gaining the safety benefits ofproximity to others, security staff, closed-circuittelevision and other monitoring.4. The living on the avails of prostitution provision canmake prostitutes more susceptible to violence bypreventing them from legally hiring bodyguards ordrivers while working. Without these supports,prostitutes may proceed to unknown locations and beleft alone with clients who have the benefit of completeanonymity with no one nearby to hear and interrupt aviolent act, and no one but the prostitute able to identifythe aggressor.5. The communicating provision can increase thevulnerability of street prostitutes by forcing them toforego screening customers at an early and crucialstage of the transaction.[101] The application judge‟s ultimate conclusion, at para. 362, bears repeating:In conclusion, these three provisions prevent prostitutesfrom taking precautions, some extremely rudimentary,that can decrease the risk of violence towards them.Prostitutes are faced with deciding between their libertyand their security of the person. Thus, while it isultimately the client who inflicts violence upon aprostitute, in my view the law plays a sufficientcontributory role in preventing a prostitute from taking