Legislating Lust: A Comparative Analysis of Prostitution Legal Frameworks in Western and Central Europe

Bethany J Murray


What, if any, improvements or modifications would you make to the current prostitution policies in your country? This was the question probed universally in interviews conducted in the Netherlands, Germany, Czech Republic, and Poland, trying to discern the most effective legal framework for prostitution. A large body of research exists against the criminalization of both supply and demand of commercial sex. However, there is growing international advocacy for criminalization of only demand, commonly known as the Swedish model. This research validates the arguments made against criminalizing both supply and demand, but criticizes the emerging international promotion of the Swedish model based on interviews and data gathered in Central and Western Europe. By using feminist methodologies in fieldwork, compiling interviews of current sex workers, activists, and advocates as well as drawing from previous scholarly work, it becomes clear that prostitution policies must be context specific and focus on providing social services and reducing the stigmatization of sex workers in order to decrease the vulnerability and increase the quality of life of sex workers, thereby improving society as a whole.


sex industry; criminalization; abolition; decriminalization; legalization

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