R v Devonald [2008]
1. Facts:
• Scenario: D, posing as a 20-year-old girl online, tricked his daughter’s ex-boyfriend into masturbating on camera to humiliate him.
• Key Issue: Application of s.76 of the Sexual Offences Act concerning deception.
2. Outcome:
• Decision: D was convicted. The court interpreted deception broadly to include not only deception about the nature of the act but also its purpose. This was a departure from the narrow interpretation seen in Jheeta.
3. Impact and Analysis:
• Broad Interpretation of Deception: This case demonstrates an expanded view of deception under s.76, encompassing purposes beyond the nature of the act itself.
• Legal Precedents: It illustrates a shift towards a broader application of deception, impacting how consent is understood in the context of sexual offences.