overwhelmingly to women and criminalised the status of "being a common prostitute" rather than criminalising the behaviours associated with prostitution. For these reasons, the original status offences for prostitution could be said to contravene the current Charter of Rights and Freedoms. Both the judiciary and the 1970 Report of the Royal Commission on the Status of Women complained about this. In 1972 section 164.1: No Apparent Means of Support Every one commits vagrancy who: (a) -not having any apparent means of support is found wandering abroad or trespassing and does not, when required, justify his presence in the place where he is found; (b) -begs from door to door or in a public place; (c) -being a common prostitute or night walker is found in a public place and does not, when required, give a good account of herself was replaced by language prohibiting soliciting (communicating) for the purposes of prostitution (section 195.1), which read: every person who solicits any person in a public place for the purpose of prostitution is guilty of an offence punishable on summary conviction. The new law was now gender neutral and defined an offence based on an act (although not the nature of the act) and was thought to have addressed the social nuisance concerns of residents. However it soon became clear that there were now new problems. In Hutt v. R. (1978) [SCC 82 D.L.R. (3d) 95] it was held that for the activities of a prostitute to be criminal their conduct must conform to the dictionary definition of "solicit"; it must be importuning, or "pressing or persistent" and constitute more than a mere indication that she was willing to prostitute herself. A plainclothes police officer permitted the appellant to enter his car. She then identified herself as a prostitute and discussed terms. The Court did not believe that this fell within the intent of parliament to prohibit acts "which would contribute to public inconvenience." Four judges indicated that they would not have considered an automobile a "public place," also excluding the actions from section 195.1. Following this there was concern that the police could no longer act against street prostitution unless there was "pressing or persistent" behaviour. Municipal initiatives Residents started to campaign against sex work as a public nuisance, primarily to have it shifted out of their neighbourhoods. The 1978 Hutt decision led to public pressure to amend section 195.1 to