R. v. Kowalski, 8 October 1987
Annual Review of Population Law 15: 146
1988
ISSN/ISBN: 0364-3417 PMID: 12289224 Document Number: 380260
The Court of Appeal of the UK held that, although a man cannot be found guilty of raping his wife because of the implied consent to sexual intercourse arising from marriage, he can be found guilty of indecent assault for forcing his wife to perform an act of fellatio. It ruled that the state of marriage does not imply consent to fellatio, even if long practiced in the marriage.