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However, another archive source documents an additional sample mention, the commission for the trial of Gavin Bell in 1645. A legal text dated 1832 added a then recent case in which a man, on confession to two acts of sodomy out of nine initially charged, was transported for life. Baron Hume wrote that "the crime is only mentioned twice in the course of our records", citing a double prosecution in 1570 and a single prosecution in 1630, with bestiality more often noted, all cases being punished by death. Recorded punishments are limited compared to purges such as the Utrecht sodomy trials, whether due to lack of offending, prosecution or surviving documentation. It reflects a former general disapproval of homosexuality and both parties are guilty of the offence". The historical legal situation for male homosexuality was severe: "The common law crime of sodomy does not involve the establishment of the absence of consent on the part of the passive agent or catamite.
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