O’REGAN J and SACHS J they are forced to work in isolated circumstances, they fear reporting assaults to the police in case they are prosecuted, and, above all, they are regarded as worthless people who bring misfortune on themselves and invite disregard for their bodies. [88] The Gender Commission, associating itself with these challenges, contested the state’s contention that criminalisation of prostitution is required in order to combat social ills “that experience has taught are as a matter of practical reality inevitably associated with prostitution”. The Commission submitted that the facts, as opposed to “experience”, reveals that the link between prostitution and harms to public health, nuisance and other criminal activities are more illusory than inevitable. The Commission concluded that the combination of false factual assertions concerning the ills inevitably linked to prostitution and their professed purpose of protecting prostitutes (belied by the form of protection offered) leads to the conclusion that the real purpose of prohibiting prostitution is the one purpose not encompassed within the identified “ills” – the enforcement of the moral views of a section of society. [89] It is not possible on the papers to resolve either the disputes of fact or those of characterisation. The Court cannot decide, for example, whether criminalisation is necessary to reduce an activity that is conducive to violence, or whether it is the criminalisation itself that establishes conditions for violence. Without doubt, the relationship between cause and effect in all these matters is complex. These are contested issues throughout the globe. Moreover, they are matters upon which Legislatures in open and democratic societies may legitimately and reasonably disagree as to the most appropriate legal response in their own society. 61