The history of prostitution in Canada is based on the fact that Canada inherited its criminal laws from England. The first recorded laws dealing with prostitution were in Nova Scotia in 1759, although as early as August 19, 1675 the Sovereign Council of New France convicted Catherine Guichelin, one of the King's Daughters, with leading a "life scandalous and dishonest to the public", declared her a prostitute and banished her from the walls of Quebec City under threat of the whip. Following Canadian Confederation, the laws were consolidated in the Criminal Code. These dealt principally with pimping, procuring, operating brothels and soliciting. Most amendments to date have dealt with the latter, originally classified as a vagrancy offence, this was amended to soliciting in 1972, and communicating in 1985. Since the Charter of Rights and Freedoms became law, the constitutionality of Canada's prostitution laws have been challenged on a number of occasions. Until the Second World War Canada originally inherited many of its criminal laws from England. The first legislation dealing with prostitution in Canada was a Nova Scotia Act of 1759 which allowed imprisonment for "lewd behaviour". Most prostitution in the early days of Canadian history took place in brothels which were in every city. Action by the authorities occurred only in the context of other criminal or socially undesirable activity taking place in or in the vicinity of these brothels such as creating a public nuisance. As in many other countries, what control there was of prostitution existed under vagrancy laws designed to keep public places free of "undesirables". Owners or operators of brothels (bawdy houses) could also be prosecuted as vagrants. These were based on the British Vagrancy Act 1824. Once the federal government came into being following Confederation in 1867, it became possible to develop common criminal laws for all of Canada. Women under 21 were protected from 'defilement' from that date, while in 1869, vagrancy provisions were consolidated and extended to include males 'living on the avails' of prostitution. The penalties were increased in 1874, and bawdy houses regulated from 1886. By a lack of suitable alternatives, women were annexed into the sex industry. Only from about 1890 was there concern about the actual existence of prostitution, with religious groups, early feminists and women's groups such as Woman's Christian Temperance Union (WCTU) and the National Council of Women of Canada campaigning for social purity and against