THEORIES AND CRIMINOLOGICAL PERSPECTIVE OF PROSTITUTION

Two of the most relevant criminological theories regarding how women slide into prostitution are the theories of general strain and labeling[1]. These theories explain the fact that most women in the sex trade do not intend to end their career as sex workers.  
General Strain Theory
There is little literature on prostitution as it relates to the general strain theory, but there is adequate literature on juvenile delinquency and drug use, which examines the general strain theory. The theory was first developed by Emile Durkheim in his study on suicide but was later refined by Robert Merton and then by Ronald Agnew in the 1990s.

Agnew  in his work, “Pressured into crime” states that,

According to general strain theory, people engage in crime because they experience strains or stressors. For example, they are in desperate need of money or they believe they are being mistreated by family members, teachers, peers, employers, or others. They become upset, experiencing a range of negative emotions, including anger, frustration and depression. And they cope with their strains and negative emotions through crime. Crime may be a way to reduce or escape from strains[2].

The strain theory proposes that crime, especially delinquency occurs as a result of the feelings generated by negative relationships with others. Prostitution frequently begins in adolescence and is considered a delinquent act. The average age of entry into prostitution, according to Farley’s study is 15. Much of the literature on sex workers paints a portrait of early childhood abuse, neglect and confusion.
It is important to note, that, it is the experience and feelings of anger and frustration from failed attempts at achievement, failure of primary relationships with caregivers, or victimization that leads to the experience of strain[3]
How people cope with that strain appears to be of two ways. The coping may be inner directed, with depression, or through substance abuse to mute emotional pain. The coping may be directed outwardly, such as violent anger, aggression etc[4]. Clearly with sex workers, the strain is mainly inner directed.

Labeling Theory
The labeling theory found its roots in the early 1930s with studies of symbolic interactionist, conducted by George Herbert Mead, who believed that the self was totally constructed in relationship to others in the society. The labeling theory, however, had its roots in a theory developed by Frank Tannenbaum in the 1930s known as the “dramatization of evil”. The theory did not fully materialize until Howard Becker presented it in 1960s in his groundbreaking book, “The outsiders: Studies in the sociology of Deviance”.
            Labeling has been called one of the most prominent theories in criminology, but it has many critics. One of the biggest criticisms is that labeling focuses on lower classes, while ignoring white-collar crime.
Once a woman enters into prostitution, often as a result of difficulties in childhood or her teen years, often coerced by relatives or pimps, it is very difficult for her to exist out of this lifestyle. This is where the labeling theory enters into the picture. Once labeled as promiscuous, or as a sex worker by the police or peers, the road to a normal way of life for such a person is often difficult and virtually impossible to navigate out successfully.
            The labeling theory may apply especially in the case of transgendered prostitutes who are doubly stigmatized both by their gender differences and their prostitution, where they experience a “host of issues ranging from sexual identity conflict, shame and isolation[5].
            There is little literature on point regarding labeling theory and prostitution; however, there is a great deal of literature available regarding labeling and drug use. A more deviant self-label at baseline predicted greater drug use in research, or follow-up, and that gives direct support to the labeling concept of resulting deviance.
Once self labeled, it is extremely difficult for the labeled person to shed his or her stigma. In addition, self-label and drug if found to be cyclical, indicates that, once adolescents categorizes themselves as drug users after that behavoiur has occurred, they are likely to stay stuck in that mind set and limit their associations to cohort, who engage in like criminal behavior[6].

Natural Law Theory
            The natural law theory posits that the standards of morality are derived from or construed from the nature of human beings. According to St. Thomas Acquinas,
The rule and measure of human acts is reason, which is the first principle of human acts, since people are by nature rational beings, it is morally appropriate that they should behave in a way that conforms to this is morally acceptable[7].

            In one of his numerous articles[8], Thomas Aquinas discusses his view on the practice of prostitution and several issues relating to this topic. However, the main question, which raises concern in his position on the social toleration of prostitution is his strong view on the morality of it.
            Historically, Aquinas notes that there has been three patterns of social policy towards prostitution. These are, toleration, prohibition and abolition, which in some cases have been enforced simultaneously[9].  The medieval period witnessed a shift in thinking concerning the social practice of prostitution. This shift was from the strict condemnation and uncompromising intolerance of prostitution `by the early church fathers.

The Religious Perspective
            The two broad religions to be considered under this are; The Christian doctrine and the Muslim Thought.

The Christian Doctrine: The bible which is the corner stone of the Christian faith is divided into two parts, that is, the old and new testaments. The bible speaks of different types of prostitutes most especially priests and priestesses to foreign gods. The practice was strictly condemned in the bible and was prevalent in the Old Testament. The kingdom of Israel had neighbours who practiced fertility rites[10] in which prostitution constituted a major aspect[11]. God detested prostitution right from the very beginning when he destroyed the cities of Sodom and Gomorrah as recorded in the book of Genesis[12]. Prostitutes are viewed with disdain, as harlotry is strongly condemned as a demonic manifestation of pagan influence, with the bible  warning against sexual union with prostitutes.
            In the new testament, the bible abhors all forms of sexual sins and called it wickedness in the church. The Apostle Paul in his epistle to the Corinthians[13]  emphasizes that that the human body is the temple of the Holy Spirit and not for sexual sins. He stressed that the body belongs to Christ and should not be joined to a prostitute.

The Muslim Thought: The Quran strictly abhors prostitution and all other forms of sexual perversion. It is stated that right from the beginning, Allah detested the acts of prostitution and homosexuality. In the Quran[14], the cities of Sodom and Gomorrah were destroyed because Allah had turned his back on the people due to their sinful lifestyle, which had loose sexual ideas as one of the points. Homosexuality is also not left out of issues that incur Allah’s wrath[15].
            Under the Sharia Law, sexual intercourse is meant exclusively for the married. Dating couples and the engaged are prohibited from having any form of carnal knowledge of each other. A person is considered a prostitute once he or she has sexual intercourse outside the confines of marriage. The punishment for prostitution is the hacking off of limb’s death by stoning.

Dichotomy between Law and Morality on Prostitution.
            What is the relationship between the legal and moral perspective on prostitution? From the inception, we can see that prostitution is morally based. The question is, “Should the issue of morality influence the legality of a particular act?” it was J.S. Mill’s[16] thesis that legal coercion could only be justified for the purpose of preventing harm to others. This view was adopted by the publishers of the Wolfenden Report on Prostitution and Homosexuality, which observed that there was a realm of private life which the law has no business.
            The report gave rise to a debate between Hart and Devlin. The debate was about the legal enforcement of morality. Devlin [17] argued that there is a public morality, which provides cement of human society. He argued that the law, especially the criminal law, has a primary function to maintain this public morality. The law should be brought into play by specific criminal sanctions, which should depend upon the state or public feeling.
            According to him, conduct which causes a wide spread feeling of re-probation, a mixture of intolerance indignation, and disgust should be suppressed by the law. He concluded that if vice is not suppressed, the society will crumble.
To him, “the suppression of vice is as much the laws business as the suppression of subversive activities”. Devlin’s view received a lot of support from the House of Lords in the case of Crown v. Brown[18], which condemned consensual and private sadomasochistic practices and held the parties liable, despite the act being consensual.
            Hart in his argument, discussed as fantastic, the notion that all morality forms a single seamless web, so that deviation from one part would inevitably produce destruction of the whole. This is contestable for the mere fact that, conventional morality may change a permissive direction, does not mean that the society is going to be destroyed or subverted.
            Devlin assured us that there is a degree of moral solidarity in human society, which have existed in earlier periods of our history but which is hardly discernable today.
            Hart [19] pointed out that the real solvent to social morality is not the failure of the law to endorse its restriction, but rather, the operation of critical discussion. He also admitted along with Devlin, some shared morality are essential to human society. This he called universal values.

The Legal Perspective.
            The law is still unprepared to fully understand the issues relating to prostitution. In some countries, prostitution carries death penalty, while it is not so in some other countries. Different countries have their legal attitudes towards prostitution. In Canada for example, prostitution itself is legal but most other activities around it are not. For instance, it is illegal to live of the avails of prostitution[20], (the law intended to outlaw pimping).
            In Argentina, 1954, a group of catholic priests were accused of plotting against the government. In retaliation, the government enacted several anti-clerical measures, which included legalizing divorce and prostitution[21]. In Bulgaria, prostitution itself is legal, but most activities around it, such as pimping are outlawed[22]. In Sweden, it is legal to sell sex but it is illegal to be a pimp, or buy sexual services[23]. The reason for this law is to protect prostitutes as many of them have been forced into prostitution by someone or some economic necessity.
            Norway has the same laws as Sweden. There, prostitutes are generally viewed by the government as oppressed, while their clients are viewed as oppressors[24]. In Netherlands, being the client or pimp is illegal but being the prostitute is not, except if the client is under-aged[25].
            In United Kingdom and France, prostitution is a legitimate business, hence, prostitution and employment of prostitutes is legal but they are regulated (with respect to health)[26]. In the United States originally, prostitution was widely legal and was made illegal in all but two states between 1910 and 1915. However in the 1980s, many states increased penalties for prostitution, where the prostitute is knowingly HIV positive.          Under the United States Criminal Code, Prostitution is contained in Article 251 as public indecency. Section 251 (2) entitled prostitution and related offences, sets out the required elements of prostitution and includes sub-section: promoting prostitution, grading of offences, presumption of living off prostitutes, patronizing prostitutes and evidence. 
The crime of prostitution is defined as follows:
1.      A petty misdemeanor, if he or she:

a.      Is  an inmate of a house of prostitution or otherwise engages in    sexual activity as a business; or
b.      Loiters in or within view of any public place for the purpose of being hired to engage in sexual activity.
         “Sexual activity” includes homosexual and other deviate relations. A house of prostitution” is any place where prostitution or promotion of prostitution is regularly carried on by one person under the control, management or supervision of another. “An inmate” is a person who engages in prostitution. “Public Place” means any place to which the public or any substantial group thereof has access.

2.  Promoting prostitution
A person who knowingly promotes prostitution of another commits a misdemeanor or felony as provided in subsection
3. Constitute promoting prostitution.

The following acts shall, without limitation of the foregoing, constitute promoting prostitution:

(a) Owning, controlling, managing, supervising or otherwise keeping, alone or in association with others, a house of prostitution or a prostitution business.
(b) Procuring an inmate or a house of prostitution of a place in a house of prostitution for one who would be an inmate.
(c) Encouraging, including or otherwise, purposely causing another to remain a prostitute.
(d) Soliciting a person to patronize a prostitute; or procuring a prostitute to a patron.
(e) Transporting a person into or within a state with purpose to promote that person’s engaging in prostitution, or procuring or paying for transportation with that purpose.
(f) Leasing or otherwise permitting a place controlled by the actor, alone or in association with others, to be regularly used for prostitution or for promotion of prostitution or failure to make reasonable effort to abate such use by ejecting the tenant, notifying law enforcement authorities, or other legally available means.
(g)  Soliciting, receiving or agreeing to receive any benefit for doing or agreeing to do anything by this subvention.

Grading of Offenses under Subsection (2)

An offense under subsection (2) constitutes a felony if:
(a)        The offenses fall with paragraph (a), (b), or (c) of subsection (2).
(b) The actor promotes prostitution of a child under 16, whether or not he is aware of the child’s age.
(c)        The actor promotes prostitution of his wife, child, ward or any person for whose care, protection or support, he is responsible. Otherwise, the offense is a misdemeanor.



(4) Presumption from living off prostitutes.

Person other than a prostitute or the prostitute’s minor child or other legal department incapable of self support, who is supported in whole or substantial part by the proceeds of prostitution is presumed to be knowingly promoting prostitution in violation of the subsection.

(5) Patronizing prostitutes
A person commits a violation if he hires a prostitute to engage in sexual activity with him or if he enters or remains in a house of prostitution for the purpose of engaging in sexual activity.

(6) Evidence
On the issue of whether a place is a house of prostitution, the following shall be admissible evidence; Its general repute, the repute of the person who resides in or frequent the place, the frequency, timing and duration of visits by non-residents.

            To be guilty of prostitution, a crime that will affect primarily women, is to be guilty of petty misdemeanor under the code. A petty misdemeanor is defined as an offense punishable by imprisonment for a maximum of less that one year. To be guilty of patronizing a prostitute, a crime that will primarily affect men, is to be guilty of a violation.  A violation is defined as punishable by fine or fine and forfeiture or other civil penalties. The code specifically provides that conviction of a violation shall not give rise to any disability or legal disadvantage based on conviction of a criminal offense.
            In Nigeria, criminal law is guided by the criminal and penal code. Chapter 21 of the Criminal code provide for offenses against morality. Prostitutes are mentioned in Section 222A as whoever, having the custody, charge or care of a girl under the age of sixteen years, causes or encourages the seduction or unlawful carnal knowledge. Or prostitution of, or commission of an indent assault upon a girl who has been seduced, unlawfully carnally known, or indecently assaulted, or who has become a prostitute. If he has knowingly allowed her to consort with or to enter or continue in the employment of any prostitute or person of known immoral character.
According to section 222B of the Criminal Code,
1.      Whoever, having custody, charge or care of a child or young person who has attained the age of 4 years and under the age of sixteen years, allows that child to reside in or frequent brothel shall be liable to a fine of one hundred naira or to imprisonment for six months or both.

Section 225A, further provides that;

1) Every person who;
a. Knowingly lives wholly or in part of the earnings of prostitution or
b. In any place persistently solicits for immoral purposes, shall be liable to imprisonment for two years.
1.                                          Any magistrate, who is satisfied by evidence upon oath, that there is reason to suspect that any premises or any part of any premises are/is used by a female for purpose of prostitution and any male person residing in or frequenting the premises is living wholly or in part on earnings of the prostitute may issue a warrant under his hand authorities any constable to enter and search the premises to arrest that male person.
2.                  Where a male person is proved to live with or to be habitually in the company of a prostitute or is proved to have exercised control, direction, or influence over the movement of a prostitution in such a manner as to show that he is aiding, abetting or compelling her prostitution with any person or generally, shall be liable to imprisonment for two years.

Furthermore, under Section 225B, it is stipulated that:

Whoever;
a.       Keeps or manages or assists in the management of a   brothel; or
b.      Being the tenant, leasee or occupier or person in charge of  any premises, knowingly permits such premises or any part thereof to be used as a brothel or for the purposes of habitual prostitution; or
c.       Being the leasee or landlord, lets the same or any part thereof with the knowledge that such premises or some part thereof, are or is to be used as a brothel, or is willfully party to the continued use of such premises or any part thereof as brothel shall be liable.

Finally, Section 226, provides that;

Any person who,

1.      Detains a woman or girl against her will in or upon any premises in other to her, being lawfully carnally known by any man, whether a particular man or not; or
2.      Detains a woman or girl against her will in a brothel, is guilty of misdemeanor and is liable for two years imprisonment.

The interpretation of a brothel in the criminal Code means any premises or room, set of rooms in any premises kept for the purpose of prostitution.

The Criminology Perspective of Prostitution
It is argued that the society is faced with the critical question of whether the criminal law should be used to regulate activities that may be considered religious or moral, but not legal issues[27]. The problem is to define acts which should be considered criminal. The definition of crime and its elements have been explored above, but the explanation does not solve the problem of which behavior should be included within those elements[28].
Sexual behaviours between consenting adults is another area in which criminal law is used to regulate private behaviors. Sex offence laws are designed to protect and preserve chastity, encompassing the whole population and proscribing everything both solitary masturbation and coitus outside wedlock called fornication. Fornication comes from the Latin word “Fornix” and it means unlawful sexual intercourse between two unmarried persons[29]. Fornication also means voluntary sexual intercourse between two unmarried persons. Fornication remains a crime under the Nigerian penal code, applied in Northern Nigeria. From the look of things, criminology is faced with the dilemma of where to place the issue of prostitution.

Victimology
Dating back to 1880s, anything resembling victimology was simply the study of crime from the perspective of the victim. The scientific study of victimology can be traced back to the 1940s and 1950s. Two criminologists, Von Hentig and Mendelsohn explored the field of victimology by creating new insight into the topic. The are considered the fathers of the study of victimology.
New victimologists began to study the behaviours and vulnerabilities of victims such as the resistance of rape victims and the characteristics of the type of people who were victims of crime, especially, murder victims. Von Hentig (1948)[30] studied victims of homicide and stated that the most likely type of victim is the ‘Depressive Type’ who is an easy target, careless and unsuspecting. The “Greedy Type” is easily duped because of his other motivation for easy gain, and this lowers his or her natural tendency to be suspicious. ‘The Wanton Type’ is particularly vulnerable to stress that occur at a given period of time in his life cycle, i.e. a juvenile victim. “The tormentor” is the victim of attack from the target of his or her own abuse such as, a battered woman. Victimology, which is a subfield or area of specialization within criminology, is defined as the:
Scientific study of victimization, including the relationships between victims and the criminal justice system i.e. the police and courts and correction officials and the connection between victims and other societal groups and institutions such as the media business and social movement[31].

A victimologist, since the subject matter is a scientific study, (dealing on empirical data, viz: collection and analysis) often uses surveys of large numbers of people about the crime, that have been committed against them because official police statistics are known to be incomplete.

Crimes Associated With Prostitution
  Assault
 In law, assault is a crime which involves causing a victim to apprehend violence[32]. In Nigeria, Section 253 of the Criminal Code Act defined assault as a misdemeanor punishable by one year imprisonment; assault with “intent to have carnal knowledge of him or her” or who indecently assaults another, or who commits other more-serious variants of assault (as defined in the Act) are guilty of a felony, and longer prison terms.
 Prostitutes in the course of business are exposed to all sorts of violence. A prostitute is a frequent target of physical and sexual assaults. From survey and research done, we can see that physical assault is associated with prostitution. Prostitutes take physical abuses as part of their lifestyle and they are trained to accept the situation helplessly[33]. The main perpetrators of this crime are the pimps, clients, corrupt law enforcement agents and random strangers. Sometimes, the prostitute is assaulted in a bid to deprive her of money (after having sexual intercourse) and sometimes the prostitute is forced to perform different forms of degrading sexual acts. Generally, a prostitute lives the life of hustling and the nature of their job requires submission.

 Rape
Black’s law Dictionary defines rape as unlawful sexual intercourse with a person (usually female) without consent. It is also termed sexual assault, sexual abuse and sexual battery. For the offence of rape, “force” need not be a criterion. So force, truly speaking, is not an element of rape in the commission of the crime.
 Prostitutes are the major targets of rapists, and based on the different surveys carried out, we can see that prostitutes are more often then not, prone to the unfortunate attack, especially where the law is prejudicial towards them. In people v. Berry[34] a rape case, the court dwells on the victim’s behavior, which it characterizes as immoral conduct. The court gave the impression that their immoral conduct is to be blamed. In the case of wood v. Alaska[35] (a sexual assault case), the plaintiff wanted to introduce evidence that the defendant was a porn-star cum prostitute, the court excluded it because it would have been prejudicial.

Murder
Prostitutes are killed every day by serial killers, clients, pimps, fanatic religious activities, etc. This is against the provision of section 33 (1)[36] of the constitution  which provides that a every person has a right to life, and no one shall be deprived  intentionally of his life, save in execution of the sentence of a court in respect of a criminal offence of which he has been found guilty in Nigeria.  The homicide rates are alarming. From time to time, serial killers and homicidal psychopaths get away with their killing of prostitutes, basically because most often, the disappearance are noticed immediately. Moreover, law enforcement officers do not put much pressure in dealing with homicide cases affecting prostitutes.
 In the case of Bedder v. DPP,[37] a prostitute called her client ‘impotent’, and was killed.
             

[1] http:// because she matters.blogspot .com/2009/06/
[2] Agnew Robert, Pressured into Crime: An overview of General Strain Theory (1st Oxford, Oxford Press, 2007).
[3] Neff, Joan L. Dennis E., and Waite, “Comparing Strain and Social learning Variables”. Justice Quartely 24 (2007) pp 106-132.
[4] Ibid.
[5] Crosby, Richard, and Nicole L. pitts. “Caught between two worlds: How Transgenerated Women may be Forced into Risky Sex.” Journal of Sex Research 44 (2007) pp. 43-48
[6] William R., Downs. “Control Theory. Labeling Theory, and the Delivery of Services for Drug Abuse to Adolescents.” Adolescence Spring (1997).
[7] Aquinas T., The Practice of Prostitution, 1991, P.1.
[8] Ibid.
[9]   Ibid.
[10] Ancient ceremonies in honour of the goddess of fertility, which involved sexual orgies amongst priests and priestesses of the Heathen Temples.
[11] Exodus 34: 15-126, Judges 8:27b.
[12] Genesis 19:24-25.
[13] 1 Corinthians 6: 19.
[14] Qu’oran, chapter 27: 54-56.
[15] Ibid.:
[16] Llyod, Introduction to Jurisprudence, (2001) 7th Edition, Sweet and Maxwell, p. 302.
[17] W. Thomas (1994) American criminal law. Pg 49.
[18] (1994) I. A. C. 212.
[19] A. H. M. Jones, The Decline of the Ancient World, 1996.
[20] Matthews R., Prostitution in London (1997),
[21] www. aboutsociology. com/sociology/prostitution.
[22] Ibid.
[23] Ine Vanwesen Beeck, “Another Decade of Social Scientific Work on Sex, A Review of Research”, P. 242
[24] http:// www. aboutsociology .com/sociology/prostitution.
[25] Ibid.
[26] Ibid.
[27] Sue Titus Reid; McGraw Hill Group, Crime and Criminology, (1997) 8th ed, , p. 18.
[28] Ibid.
[29] Black’s Law Dictionary, op cit .p. 664.
[30] Von Heintig; The Criminal and His Victim, New Haven press, 1949.
[31] Andrea Karmen, “Crime Victims: An Introduction to Vitimology,” A Journal (1990).
[32] En.Wikipedia.Org(Wiki/Assault).
[33] Mim H. Sobert and Ayalam. Pines, Early Sexual Exploitations as an influence to prostitution work, (1983), p 285.
[34] People v. Berry (1909) Ac pg. 220.
[35] 957 F. 2d 1544
[36] 1999 Constitution  of the Federal Republic of Nigeria (As Amended).
[37] Bedder v. DPP (1954) 1, WLR 119
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