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Since the matter has not been determined by the Supreme Court of Canada, it is still possible that a woman could be convicted elsewhere in Canada, but interpretation of moral law in Canada has become increasingly liberalised.
There do not appear to have been any further women charged in Canada since these cases were decided.
He added that parks require clothing, except, for example, the clothing optional Hanlan's Point Beach.
On July 19, 1991, a very hot and humid day, Gwen Jacob, a University of Guelph student, was arrested, after walking down a street in Guelph, Ontario, while topless after removing her shirt when the temperature was 33 °C (91 °F) and was charged with indecency under Section 173(1)(a) of the Criminal Code.
In 1997, Fatima Pereira Henson was charged with trespassing for swimming topless in Cambridge, but the charges were dropped.
However, what constitutes an indecent act is not defined, and is open to interpretation by the courts.