Following Operation Spanner, the European Court of Human Rights ruled in January 1999 in Laskey, Jaggard and Brown v. United Kingdom that no violation of Article 8 occurred because the amount of physical or psychological harm that the law allows between any two people, even consenting adults, is to be determined by the jurisdiction the individuals live in, as it is the State's responsibility to balance the concerns of public health and well-being with the amount of control a State should be allowed to exercise over its citizens. In the Criminal Justice and Immigration Bill 2007, the British Government cited the Spanner case as justification for criminalizing images of consensual acts, as part of its proposed criminalization of possession of "extreme pornography".House of Commons: Criminal Justice And Immigration Bill Another contrasting case was that of Stephen Lock in 2013, who was cleared of actual bodily harm on the grounds that the woman consented. In this case, the act was deemed to be sexual.
