Criminal Law Doctrine and Women Who Kill - Essay Example

Background Topic: Criminal law doctrine seems utterly incapable of dealing with women who kill. Either they are deemed monstrous and receive sentences that cannot be justified under any rational scheme of punishment, or they are treated with undue chivalry. Fiona Bookman writes in Understanding Homicide that there exist widely held beliefs among criminologists about the nature and morality of women with regard to the nurturing role of a woman as a wife and a mother. Feminity and womanhood are generally associated with an absence of criminality, and women are universally judged on the basis of these virtues. Thus when women do not conform to the male-dominated sex role expectations of what it is to be a good wife, good mother and therefore a good woman, they are then considered to be 'doubly deviant' and punished for both their legal infringements as well as their refusal to conform to the female gender behaviour. This becomes all the more relevant while considering that the bulk of female homicides involve the killing of those closest to them that is, their spouses, lovers or infants thereby contradicting all concepts of motherhood, wife and woman. She further writes that when women kill it is typically not to terminate violence on their part, nor to gain any power over their male partners. Instead it is usually an attempt to get some degree of final and desperate control and relief for themselves from their abusive partner especially at that point when they realise that their very life is being threatened. Patricia Pearson, Toronto based author of the hard-hitting book on female violence When She Was Bad: Violent Women and the Myth of Innocence, says women get off the hook for violent crimes because society will not admit they can be predators. According to her some women are getting away with murder simply because they're women. She argues that legal defences, portraying the murdress in a battered-women's syndrome, and misogynistic attitudes are giving some women a social licence to kill and be violent because society considers it too intimidating to admit that women can be capable of ruthless crimes just like men. She writes that society would rather think ofviolent women as hopeless, weak or child-like creatures more likely to have been abused or being simply crazy. To prove her point she gives the example of women like the wicked Karla Homolka, who was guilty of helping to kidnap, sexually torture and kill three teenage girls, including her own sister. However, after winning a plea-bargained 12-year sentence she sat happily in her prison cell reading the books Battered Women and Perfect Victim. "It worries me when people begin to feel entitled to use violence because they've bought so deeply into the idea of their own victimization," Ms. Pearson said during an interview. "The whole idea of learned helplessness is, you're so helpless you can't walk out the door and therefore, somehow, you're able to discover the strength to shoot the guy in the head. I think a larger number of women than we realize get away with murder for a whole number of different reasons." "We don't want to take female violence seriously because I think we have our hands full with male violence and I think that we have an idea of women as being the people that you go to for your shelter. Out there in the mad and dangerous world at least you can go home at night to a sweet and comforting hearth. We can't accept the fact that we can't go home to a safe house." Ms. Pearson is highly critical of some feminists who, according to her, are trying to keep the issue of female violence hidden. This allows society to avoid admitting that women, like men, can commit violence for an elaborate variety of reasons, and not simply on account of madness or in self-defence. This also permits these feminists to continue depicting women as sufferers rather than predators. The silence on the issue, she says, is making sacrificial lambs out of men who are victimized by violent spouses, mothers and other women. "These guys are pariahs because we're so preoccupied with our fear of what other men are going to do with female aggression statistics. The male victims of spousal assault are sort of the sacrificial lambs to our political concern with violence against women." Ironically, one of the reasons she decided to write this book was to espouse the cause of feminist equality. "We have to get a grip on the capacity for women to be injurious, on women's terms. We have to stop just reacting against how men define us by saying, 'No, we're not that way, we're good, we're this, we're that' and say, 'Well, you know, yes we are complex and we do things that aren't necessarily, what is that term, sugar and spice But we're responsible for them (violent actions) and we want to examine them on our terms and sort them out, develop our own sort of sense of moral accountability and have a better understanding of our own power.' "I think it's terribly justified for women to kill men when they're situationally trapped," she says. "I think they should just be able to do it rationally, just say, 'What would you have done in my shoes It was rational self-defence.'" In fact, she got the idea for the book while covering the 1995 Paul Bernardo murder trial and watching Ms. Homolka testify. "I couldn't believe that there wasn't any other explanation for her but that she was battered. I just thought that was nuts. I started to look into it and I realized that there was very little research on female aggression and that there had to be alternative explanations that presumed that women were complex and that they were powerful and ambitious and they were capable of being rageful and wrathful and so on." What she found, she writes in the book, is that "although self-justification (for a violent act) is universally human, the vocabulary of motive is different for male and female offenders. Because we won't concede aggression and anger in women, the language we use to describe what they do is much more limited, and much more exonerative." "There exists perhaps three or four rationales for the whole, extraordinary diversity of violent acts women commit, and they all play into pre-existing prejudices about female nature." "The operative assumption is that the violent woman couldn't have wanted, deliberately, to cause harm. Therefore, if she says she was abused/coerced/insane, she probably was." Ms Pearson was particularly critical of Ontario Judge Lynn Ratushny who completed a two-year review of 9 cases of women convicted of murder and manslaughter. The women had claimed that they killed the abusive men in self defense. The result of the review by Judge Ratushny was that the federal government pardoned two women and erased the remainder of some 30 or 40 women's murder sentences. Ms Pearson said, "My argument to that would be, that everybody who commits a violent crime perceives themselves as threatened, and that includes serial killers." In the book, she writes: "By the time Homolka took the stand in 1995, the standard of what degree of brutality a woman must sustain before she succumbs to this 'syndrome' had eroded to the point of insulting plausibility." Soon after the book was released, Ms. Pearson was targeted by some women for what they considered an offensive piece of work. "For far too long we've been afraid that men are going to define our positions for us. We have to get past that and say 'Well fine, a couple of neo-conservative lunatics are going to say, 'See women do it too, ha, ha, ha,' but the vast majority of people are maybe actually going to gain a much greater understanding of a very complex subject and that's, to me, worth the risk." "I think it's really important that we understand that if we're going to look at causes of violence, we stop looking at it in gender terms, because you can't understand a man who beats his wife if you don't understand that he may have been beaten by his mother and may have become a misogynist. Not that it's always that simple, but it's not useful to look at it purely in gender terms. There are contributions going back and forth between females and males in cycles of aggression." Traditionally, men have not been able to admit to violence in women as most of the violent crime and criminal types have centered on males with the idea that men are the more aggressive, violent and criminally inclined than women. This can also be attributed to the fact that most of the researchers and historians of crime have been men. Women are still viewed as soft and vunerable and not outfitted to be the criminal types, perhaps playing more of a role as accomplices in crime. One male writer has gone to the extent of stating that it would be extremely cruel to let a 'beautiful' woman who had killed 20 people to "choke to death" at the end of a hangman's rope. He certainly wouldn't have said the same if it was a man. Most of the researchers continue to claim that even in crime women are the 'gentler' sex conveniently overlooking the fact that they have often killed with axes and guns and not just with poison. Infact women outnumber men in the killing of chidren and equal them when it comes to killing of parents and siblings. Women have been known to be just as cold-blooded as males but they have more often been projected as what women are supposed to be like rather than what they really are like. In the study of 62 female serial killers in Serial Murders and Their Victims by Eric Hickey these women accounted for 400 to 600 victims. (Although unlike men women are not known to mutilate the corpses of their victims). People are horrified by women who kill their own children, inspite of their supposed 'maternal instincts' and poison their husbands, or hire some one to kill them, after having 'professed love for them'. It is for this very reason that women serial killers are allowed to get away for longer periods because we don't want to recognise them as 'killers'. Hickey reports that women are involved in serial killings 38 percent of the time. History of criminal justice in England over the past fifty years have largely ignored crime by women or if there is any reference it is more likely to refer to 'female' offenses such as infanticide, prostitution or witchcraft or to especially scandalous or shocking cases. Historians of crime have largely ignored crimes by women. This only highlights the conservative perception of modern day historians that crime has always been a male activity. This has resulted in a collossal error apart from failure to accord women an equal treatment. It appears that scholars of crime have been blind to the historical facts. During the eighteenth and nineteenth century England, Netherland and elsewhere women comprised thirty to fifty percent of those charged with serious crimes. This readily available data has been ignored by the historians. Women crime historians have performed a moderately better job of highlighting of serious crimes by women. It appears that men became 'blind' when reporting serious crimes by women. However this high proportion of serious crimes by women declined towards the latter part of the eighteenth and most of ninteenth century till they reached present day levels by the late ninteenth century. It is an unsolved mystery as to what caused this marked decline in serious crimes by women. However in recent years some social scientists have addressed this issue prominent among them being University of Toronto historian John Beattie who was probably the first historian of the English criminal process to dedicate significant attention to the subject of women and ordinary crime. His epic study,Crime and Courts in England: 1640-1800 devoted an extensive chapter to an examination of the high levels of women charged with serious criminal offenses in England. John Hagan, another University of Toronto sociologist and his colleagues have traced the decline of women charged with serious crimes in Toronto. Lucia Zedner, an Oxford legal historian has written a serious book on women and crimes during the Victorian era in which she attributes the decline of women charged with serious crimes to a swing in the popular attitudes towards women. This swing was as a consequence of branding them mad instead of bad and shunting them away from the criminal process into the then recently emerged mental asylums. Lucia Zedner's fine but incomplete work into women and crime in the late Victorian England calls for more investigation by succeeding historians. Judith Knelman's book,Twisting in the Wind: The Murderess and the English Press, also focuses on women murderers in the nineteenth century. As per her observation on women in the nineteenth century, "there was a significantly higher participation rate for women in murder than in other crimes". She studied the backgrounds of deprivation and oppression of murderesses; their motives and methods; and how they fared in the criminal process; how the types of murders women committed transformed over time; and how the treatment of female murderers differed from the way male murderers were treated. She went on to explore how murderesses were depicted in the press, and the various forms the popular press took in the nineteenth century. According to her the Victorian press viewed murderesses according to some pre-set concept of 'femininity'. In each chapter of her book she writes about a different type of murder: multiple murders; murder of husbands, lovers, or rivals; baby farming and infanticide; murder of and by servants; murders of the aged. Each type of murder has been treated in a similar fashion, such as giving the circumstances of the murderesses, their journey as a criminal, and how they were portrayed in the press. Baby farming involved giving out infants for adoption with the understanding that the caretakers would let the child die through malnutrition, poisoning, or failure to treat their illness. Another popular form was poisoning of family members to claim their insurance benefits. This type of crime gradually disappeared with improved methods of chemical testing and with insurance companies developing more sophisticated techniques of investigation. She goes on to examine the evolving of womens sexuality in the Victorian era and how this was depicted in the popular press. It included portraying the images of the murderesses, the feminine angle and their 'sexuality'. This book is supposedly an academic study into an under-examined field; it has a lot in common with other sensationalized records of murderesses published in the nineteenth century. The book emphasises the 'extraordinary' and 'sensational', rather than the routine and the commonplace crimes reported in the popular press. However an important and intriguing contribution of this book is that it presents considerable statistical data while comparing male and female murderers which reveals that women committed roughly one third of all murders in the nineteenth century, a proportion much higher than in the twentieth century. For instance, she has referred to the reductions in crimes of poisonings after a flurry of arsenic poisonings in the 1840s led to a legislation banning over-the-counter sale of arsenic. Nevertheless Twisting in the Windis an important contribution to the study of women and crime. Its major contribution lies in the shift from an earlier focus on "female" crimes and goes on to explore the wider scope of women's criminal activity. Its findings highlight the importance of examinining in greater depth women's criminality in the nineteenth and the preceding centuries. Twisting in the Wind, by providing valuable information on little-known criminal practices, joins one of a growing number of studies by women on the history of women's crimes. MEDA CHESNEY-LIND in her essay From invisible to incorrigible: The demonization of marginalized women and girls refers to Faludi, S. (1991) Backlash: The Undeclared War Against American Women.: Feminist attention to male violence against women has been countered by backlash arguments that women are just as violent as men, but play the 'victim' role better, how certain behaviors or appearances are labeled as 'masculine' and why, when they occur in women, they are considered deviant and harshly punished. At its core, the 'bad girl' hypothesis is that the women's movement has a 'dark' side, encouraging girls and women to seek equality in the illicit world of crime as well as the licit labor market; Freda Adler, for example, wrote in her path-breaking book, Sisters in Crime (1975a) that 'the movement for full equality has a darker side which has been slighted even by the scientic community. In the same way that women are demanding equal opportunity in the elds of legitimate endeavor, a similar number of determined women are forcing their way into the . . .world of major crimes' Bishop less than a decade later stated "that in the ght for emancipation women have won most of their objectives and they have good reason to be jubilant at their success. Yet, could they have foreseen the future twenty years ago, they would probably have relinquished the struggle, afraid of the consequences of their coming triumphs . . . speaking broadly, it is my belief that many more women have become criminally minded during the past few years than ever before . . . they have shown greater imagination and, in some cases, greater initiative than men." Coming back to the UK we have British phlanthropist Lord Astor putting it in direct terms, "Everyone starts out totally dependent on a woman. The idea that she could turn out to be your enemy is terribly frightening." With reference to case law in UK we have the case of Ruth Ellis who was the fifteenth, and the last woman hanged in England in the twentieth century. She was also the unluckiest. Her case was a true tragedy of British justice. She was a statistic, one that would trouble the conscience of the British legal system ever since. She did not kill for any gain and, had the trial judge permitted her defense to be put to her jury, they may in all likelihood have found her guilty only of manslaughter. At her trial on Monday, June 20th, 1955, Ruth appeared in the Number One Court at the Old Bailey in London before Mr. Justice Havers. Her lawyers had tried to get her to play down her appearance, but Ruth was determined to have her moment of stardom. Her appearance at the trial was that of a hard-faced tart. The defence had desperately wanted to create an impression of a bewildered, emotionally crippled victim. The trial lasted just a day and a half; the evidence against her was simply too overwhelming. She had a gun; she shot her lover dead in cold blood. End of story. The jury found her guilty within 23 minutes but really had no other alternative. Although her lawyers had tried to create a defence, that Ruth was so consumed by her jealousy that she was incapable of a premeditated murder, the judge ruled against this. He briefed the jury painstakingly on the differences between murder and manslaughter. Their decision quite simply hinged on whether or not Ruth fired deliberately into David Blakely's body. The jury decided she did. Mr. Justice Havers confirmed the only sentence he could, committing Ruth to "a lawful prison, and thence to a place of execution, and that there you be hanged by the neck until you be dead." Member of Parliament, George Rogers, tried to convince her to let him petition for clemency on her behalf. Fifty thousand signatures on a petition for mercy were sent to the Home Office. But probably Ruth was done in by huge publicity that her case had created; for this may have convinced the Home Secretary that he would seem to be succumbing to public pressure if she was spared and diluting the principal of capital punishment to which his government was resolutely committed. One of Britain's foremost newspaper columnists William Connor argued forcefully for her clemency. However, Mrs. Gladys Kensington Yule, the banker's wife who was shot in the hand by one of Ruth's stray bullets was a highly vocal witness against her. Mrs. Yule was a strong advocate of capital punishment; her near-brush with death made her actively fight against any clemency to Ruth and in this she was extremely successful. On July 11th, Ruth was informed of the news that the British Home Secretary, Major Gwilym Lloyd George, had turned down any reprieve. The British public had gone to a general election on May 26th. Had the Labour party won it was expected that a Labour Home Secretary would have undoubtedly commuted her death sentence to life imprisonment, which generally meant a maximum of twelve years. But for Ruth it was not to be. Ruth's execution made news around the world. One Paris newspaper wrote that the British legal system symbolised "a pitiless legal system which, alone in the world, refuses to recognise the human sentiments of life." In America, there was unanimous consensus that Ruth should not have hung. In Australia, a Melbourne newspaper carried an article "Hanging shames Britain in the eyes of the civilised world." Theheadlines in Aftonbladgetin Sweden cried: "The continuance of the death sentence in England is a burden for England's good name in the world." The notion of thecrime passionnelappears foreign to the British, observed a majority of foreign newspapers. One French reporter wrote: "Passion in England, except for cricket and betting, is always regarded as a shameful disease." In 1974 Albert Pierrepoint, her hangman, ironically wrote, "I have come to the conclusion that executions solve nothing. It is said to be a deterrent. If death were a deterrent, I might be expected to know. It is I who have faced them last, young lads and girls, working men and grandmothers. It did not deter them. All the men and women who I have faced at that final moment convince me that in what I have done I have not prevented a single murder." Labour's solicitor general Vera Baird, whose Party took the necessary steps to change the law, wrote that the law is"both too lenient on those who kill out of anger and too harsh on those who kill out of fear of violence". The main changes to the law of homicide dealt with provocation. Prior to that people who killed after being provoked into losing their self-control might have had a defence to murder. But it was not a full defence, which could result in an acquittal. Provocation is a partial defence, meaning that it leads to a conviction for manslaughter rather than murder. This is critical only because murder attracts an automatic sentence of life imprisonment, whereas the sentence for manslaughter is within the court's discretion. After the change, the common law defence of provocation would be abolished and replaced by a new law. It would no longer matter whether the killer's loss of self-control was sudden. Anthony Edwards, a leading criminal solicitor, said that this will make it "easier for the defence, particularly in respect of battered women, to run the slow-burn defence where a person has been subject to abuse over a long period of time when a final small act leads to the killing". The recognition of the distressing effects of long-term domestic abuse was confirmed by the case of Kiranjit Ahluwalia whose conviction for killing her husband was reversed on appeal in 1992. After abuse, which including having a hot iron held to her face, she attacked him while he was sleeping by pouring petrol on him and setting him alight, but he died and she was charged with murder. Her appeal created a historic precedent - that women who kill as a result of harsh domestic violence should not be treated as cold-blooded murderers. As in the case of Sara Thornton, Ahluwalia's case showed they could still have a defence, even if they did not kill in response to an immediate act of violence. During her troubled marriage with her husband, Malcolm, Sara Thornton suffered repeated beatings. She complained to numerous agencies, called the police repeatedly as a result of which her husband was eventually charged with assault. But he was killed before his court appearance. As he lay drunk on the sofa one night in June 1989, she stabbed him to death. After her trial she was convicted of murder and given a life sentence by a judge who said she could have simply "walked out or gone upstairs". Sara Thornton became a cause clbre for feminists agitating against domestic violence. Thornton appealed against her conviction, arguing that she killed as a result of "slow burn" provocation. She lost. Two days later, Joseph McGrail killed his wife, as she lay drunk, by kicking her repeatedly in the stomach. He got away with a two-year suspended sentence for manslaughter and walked free. The judge showed great sympathy for McGrail, adding "this lady would have tried the patience of a saint". In response to the glaring discrepancy in treatment, the feminist law reform campaign Justice for Women (JfW) was born in 1991. Men are guilty of committing almost 90% of domestic homicides, and the victims are generally their female partners - who have often suffered being battered by their killers. On an average, two women are being killed every week due to domestic violence. However, the defence of provocation is made-to-order for men who kill their female partners. Provocation will usually reduce a murder charge to that of manslaughter if the defendant can prove that things were said or done to provoke them, resulting in a sudden loss of control. In such cases they claim that they "just snapped" or "saw red". Judges generally express sympathy for men who claim they were nagged or cheated by their female partners, but don't have the same sympathy for women who kill after being raped by their partners or after suffering domestic violence. Courts generally feel that when women, who are being regularly beaten by their partners kill, they usually act out of fear or despair - which cannot be equated with a sudden, volatile "loss of self-control". Under usual circumstances, the response to the provocation is likely to be an almost immediate retaliation. If there is a "cooling-off" period, the courts find that the accused would have regained control, and all following actions would be pre-meditated and therefore murder. Even the time required to fetch a weapon should be sufficient to 'cool off'. Thus in theR v Thornton(1992) 1 AER 306 Sara who was suffering from "battered woman syndrome" went to the kitchen, took and sharpened a carving knife, and returned to stab her husband. In her appeal the jury was asked to have regard to "everything both said and done according to the effect which in their opinion it would have on a reasonable man". The appellant argued that the jury should have considered the events over the years leading up to the killing instead of only the final provocation. However, Beldam LJ, rejected this, saying "In every such case the question for the jury is whether at the moment the fatal blow was struck the accused had been deprived for that moment of the self-control which previously he or she had been able to exercise." But inR v Thornton (No 2)(1996) 2 AER 1023 the court, after considering new medical evidence, ordered a retrial and the defendant was convicted of manslaughter on the ground of diminished responsibility. Similarly, inR v Ahluwalia(1992) 4 AER 889 a retrial was ordered. The defendant had poured petrol over her husband and set it alight, causing burns from which he died. When the defence of diminished responsibility on the ground of "battered woman syndrome" was put, she was convicted of manslaughter. InR v Humphreys(1995) 4 AER 1008, the defendant finally lost self-control after years of abuse and stabbed her partner. She pleaded that the final words had been the last straw that broke the camel's back. The conviction for murder was held unsafe because the accused's psychiatric condition stemming from the abuse should have been attributed to thereasonable person when the jury considered the application of the objective test. Conclusion: We have studied the huge swing in the applicability of the criminal law doctrine while dealing with the different cases of women murders. From the case of Ruth Ellis to those of Kiranjit Ahluwalia and Sara Thornton there has been considerable irrationality in the application of the homicide law. However, the inadequacies of the criminal law with respect to female homicides are underscored by reading the following recomendations made by The Law Commission on Partial Defences to Murder in the CONCLUSIONS ON THE ADEQUACY OF ENGLISH LAW IN RELATION TO ABUSED WOMEN WHO KILL: 1. We consider that the law does not always deal satisfactorily with abused women who kill, especially by comparison with the way in which it treats certain other types of killing. If a woman in an abusive relationship kills her partner in order to protect herself from further violence, she may have no defence to murder (under provocation, diminished responsibility or self-defence). She is therefore punished with life imprisonment in circumstances where such a sentence may be considered disproportionate to her culpability. But if her partner in a sudden rage kills her because she has been unfaithful, he may succeed in a defence of provocation and be convicted of the lesser offence of manslaughter, even though his culpability might well be considered to be greater. 2. In order to remove this unfairness, the law would have to be altered in one of two directions. 3. One approach would be to abolish the mandatory life sentence. A judge would then have discretion in sentencing a woman who has killed her abusive partner. However, unless the defence of provocation is also abolished, there would still be a real possibility of inequity between an abused woman who kills and that of a man who kills his partner in circumstances entitling him to the defence of provocation. 4. The other approach would be to extend the availability of a defence to murder to an abused woman who kills either by altering the boundaries of an existing defence or by creating a new defence. 5. Any reform of the law needs to be both principled and practicable, taking into account not only its application to cases of abused women who kill but also its wider potential effect. References 1. Anne Jones: Women Who Kill - Google Books 2. e-Lawresources.co.uk : R v Thornton [1996] 1 WLR 1174 http://www.e-lawresources.co.uk/forum/viewtopic.phpf=81&t=581&view=previous Fathers For Life: When She Was Bad: Violent Women and the Myth of Innocence http://fathersforlife.org/fv/when_she_was_bad.htm 3. Fiona Brookman: Understanding Homicide 4. From invisible to incorrigible: The demonization of marginalized women and girls http://www.sfu.ca/wchane/sa460articles/Chesney-Lind.pdf 5. Guardian.co.uk: Battered women who kill to be main beneficiaries as homicide law changes http://www.guardian.co.uk/law/2010/sep/30/murder-law-reform 6. Guardian.co.uk: women who kill violent partners treated unfairly in court http://www.guardian.co.uk/lifeandstyle/2009/jun/26/women-kill-violent-partners-law http://www.lawcom.gov.uk/docs/cp173.pdf 7. Homicide-Voluntary Manslaughter http://www.lawteacher.net/criminal-law/cases/voluntary-manslaughter.php 8. Judith Knelman's: Twisting in the Wind: The Murderess and the English Press 9. Judith Knelman.Twisting in the Wind: The Murderess and the English Press. - Book Review http://www.h-net.org/reviews/showrev.phpid=3047 10. Meda Chesney- Lind and Lisa Pasko: The Female Offender: Girls, Women and Crime http://en.wikipedia.org/wiki/Meda_Chesney-Lind 11. Patricia Pearson: When She Was Bad Violent Women and the Myth of Innocence 12. Polly Pattullo: Judging Women - Google Books http://books.google.co.in/booksid=d4gOAAAAQAAJ&pg=PA132&lpg=PA132&dq=polly+pattullo+-+judging+women&source=bl&ots=D7H3XZYEDD&sig=2iNKba1aE4 13. Principles of Criminal Law: Hobson [1998] 1 Cr App R31 - Google Books 14. Ruth Ellis: The Last to Hang http://www.trutv.com/library/crime/notorious_murders/women/ellis/12.html 15. The Law Commission: Partial Defences to Murder http://www.lawcom.gov.uk/docs/cp173.pdf 16. Trutv.com: Notorious Murder - Women Who Kill http://www.trutv.com/library/crime/notorious_murders/women/women1/1.html 17. When she was bad: Violent women and the Myth of innocence by Patricia Pearson - Book Review: http://www.menweb.org/whenshe.htm 18. Wikipedia: Provocation in English Law http://en.wikipedia.org/wiki/Provocation_in_English_law 19. Wikipedia: Meda Chesney-Lind http://en.wikipedia.org/wiki/Meda_Chesney-Lind Read More