26 (ii) exposing the child to maltreatment, abuse, degradation, ill-treatment, violence or harmful behaviour towards another person’. [61] Counsel for the appellant also contended that, by way of international comparison, there are ‘many examples’ of European countries which set lower age limits for legal consent, to both same-sex and heterosexual sexual acts, than those stipulated in s 14(1)(b) of the Act. He also pointed out that there are ‘many examples’ of European countries which have eliminated any previous distinction that existed in such countries between same-sex and heterosexual legal ages of consent. While the latter contention is certainly true of both European countries and other countries in the world, the former contention is not entirely correct. As far as I have been able to ascertain, there are very few countries where the legal age of consent for heterosexual sexual activity is lower than 14 years, while by far the majority of countries set the legal age of consent in this regard at 15 or 16 years, or even older. The age of consent for sexual acts is uniform for homosexuals and heterosexuals in the majority of countries outside South Africa. It would appear that most countries have set this uniform age at 16 years, whilst there are some who have set it at 18 years and an isolated few at between 13 and 15 years.1 [62] There is a world-wide and growing awareness of the particular vulnerability of children and of the fact that child abuse, including sexual exploitation of children, is a serious and ever-escalating problem. In South Africa, unfortunately, the extent of this problem is truly appalling. Some of the (alarming) statistics and of the factors that 1 See htpp://www.ageofconsent.com/ageofconsent.htm, accessed 4 March 2008 and also http://www.avert.org/aofconsent.htm, accessed on 4 March 2008). Both these websites contain very useful and comprehensive tables listing the ages, in most countries of the world, at which people of various sexual persuasions (heterosexual, gay and lesbian) can legally consent to voluntary vaginal and anal intercourse, as also to other sexual activities. The table from the latter website, headed ‘Worldwide ages of consent’, is annexed to the respondent’s supplementary heads of argument. This website notes that, in many countries, the legal age of consent is higher when one partner is in a position of trust with regard to the other, or one partner takes advantage of the other’s immaturity (see for example, s 3(1) of the United Kingdom Sexual Offences (Amendment) Act of 2000, s 153(1) of the Canadian Criminal Code and Article 207(b) of the Austrian Criminal Code, as introduced in 2002). It is also noted that the average legal age of consent across the world for heterosexual, gay and lesbian persons is 16 years.