Hannah J.  Elizabeth
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‘If it hadn’t been for the doctor, I think I would have killed myself’
Ensuring adolescent knowledge and access to healthcare in the age of Gillick

In 1985, after years of campaigning, Victoria Gillick won her battle in the Court of Appeal and removed adolescents’ rights to freely access sexual health advice and contraceptives. The case, its implications, and its after-effects were widely reported in the teenage press. This ruling, later overturned by the Law Lords, plunged teenagers, teachers, and doctors into a period of uncertainty about what information and contraceptives could be freely given to those below the age of sixteen. This confusion threatened teenagers’ access to NHS healthcare long after the ruling was overturned as teenagers were left unsure of their rights to knowledge and contraception. Ironically, Gillick’s intervention was treated as an opportunity to provide sexual health information, open discussions around consent, and bolster teenage agency at a time when it seemed to be under threat. By exploring the representation of teenage access to contraceptive services, the Gillick case, and ‘Gillick competence’ through teenage media, this chapter demonstrates how access to NHS healthcare is mediated by knowledge of our rights.

To help you look after yourself, here is a brief guide to your rights under the National Health.

Everyone living in Britain has a right to free treatment […]

If you are under 16, your doctor is chosen for you by your parents. That doesn’t mean, however, that the doctor can tell them everything you’ve said or that you have to accept treatment if you disagree with what your parents want.

For instance, if you ask your doctor for contraception your doctor can refuse you but unless you give permission, shouldn’t tell your parents.

‘Facts of Life: Dealing with your Doctor’, Just Seventeen, 9 February 1984, pp. 20–1 (emphasis in original)

For the teenage readers of the new magazines for girls which emerged in the 1980s,1 sixteen loomed large as the threshold at which sexual intimacy became legal between heterosexual adolescents.2 In England and Wales between 1984 and 1985, sixteen also came to represent another equally intimate milestone: the age at which teenagers were deemed capable in law of medical autonomy and afforded the right to choose their doctors and treatment courses, and crucially, to confidentially access contraceptive information and technologies without parental consent or knowledge. Before and after this moment, an adolescent’s ability to confidentially access free contraceptive services was limited not by their age, but rather by their capacity to consent – assessed by a doctor – their own ability to seek help, and the views of their doctor regarding contraception. This chapter discusses this moment through the prism of teenage magazines’ responses to Victoria Gillick’s attempt to place contraceptive knowledge and technology beyond the reach of under-sixteens in Britain.

As I have argued elsewhere regarding the AIDS crisis,3 it is appropriate to explore moments like the Gillick case through the polyphonic pages of magazines like Just Seventeen because these spaces were important sites where many teenage girls encountered information on sexual health and their health rights for the first time, learning how to be healthy citizens and (future) sexual citizens.4 Indeed, a working paper commissioned in response to the 1995 Luff Bill (which had hoped to age-restrict teenage magazines because of their sexual content) indicated that teenage magazines held a pivotal role in sexual health education, noting that young people preferred ‘to get their information on sex from printed sources rather than from adults’.5 The problem pages of newspapers had long held a role in the sexual health and relationship education of Britain’s public,6 but as the persistently inconsistent sex education provision for Britain’s youth was wracked by ever more indecision and devolution during the 1980s, teenage magazines discovered the profits to be made by filling this sex education vacuum for the young.7 Editors, agony aunts, and freelance feature writers began producing problem pages, advice columns, special feature articles, and true-life-confession stories which made up for the uncomfortable silences in school and at home around the subject of sex, sexual health, and sexuality.8 Magazines even collaborated with sexual health charities, like Brook, a British charity focused on young people’s sexual health, and the Family Planning Association (FPA), to bring accurate content on health and sexual health services to their young readers.9 This accurate information was framed as empowering, but also rare and enticing, with readers encouraged to accumulate knowledge (by buying Just Seventeen) without enacting it. This version of knowledgeable but abstaining healthy teenage sexual citizenship was later encapsulated in Just Seventeen by the mantra ‘Remember: to be sussed is a must, but sex under 16 is illegal’ (emphasis in original), which appeared as a border on all problem pages from 1994.10

The inclusion of sexual health education in the pages of teenage girls’ magazines was a major marker of change in the youth magazine market. The new magazines of the 1980s bore little resemblance to the conservative publications of previous decades like Jackie or Bunty,11 reflecting a change which had taken place in youth, consumer, and sexual culture more generally.12 Unbounded by the legislation, professional oversight, and the scrutiny which governed educators and doctors, magazines could offer information about sexual health and sexuality without the interference experienced by these professionals. Indeed, magazines repeatedly used changes in legislation as an opportunity to critique the Conservative government and sex education more generally.13

This chapter outlines how teenage health rights within the National Health Service (NHS) were presented in the market-leading magazine Just Seventeen during the high-profile period when Gillick challenged the availability of contraception for under-sixteens, changed legislation, lost her appeal in the law courts, and ultimately became the eponym for the definition of the competent child. The chapter demonstrates how magazines promoted the idea that knowledge of and access to NHS services (especially those relating to sexual health) were an integral part of healthy adolescent selfhood and citizenship. Indeed, as this chapter will argue, Gillick’s challenge to teenage agency was treated by Just Seventeen as an opportunity to provide the very contraceptive information Gillick wished to prohibit, and to promote the idea that its typical readers were perfectly capable of deciding how to access the NHS without parental oversight, regardless of age. Through discussions of contraceptive access, teenage girls were introduced to their wider health rights and encouraged as both individuals and members of a collective to access the NHS – consuming information and services – in order to guard their health. They were asked to invest ideologically in healthy citizenship (and by extension the NHS) as an ideal of teenage femininity, and prepared for a future where they would contribute to the upkeep and maintenance of the NHS, not just through ongoing personal healthful behaviours, but financially as they became earning citizens, paying – as one article explained – ‘£18 per family each week’.14 In this way, Just Seventeen was able to position Gillick’s objection to teenage contraception access as not just anti-adolescent rights, but also anti-health and, critically, in contravention of the principles of the NHS.

‘Gillick competence’ is the label used to describe a child under sixteen who has been deemed to have the capacity to give informed consent within specific legal and medical settings. This capacity affords the ‘Gillick competent’ child the right of consent or refusal for medical or legal treatment, which adult professionals are duty-bound to offer, in order to ensure their wellbeing, even should such treatment be in contravention of their parent’s or guardian’s wishes. The legal case from which this label emerged sought to create no such protective framework for children, nor did it really seek to debate children’s capacity to consent. Rather, Victoria Gillick’s legal challenge aimed to bolster, exert, and protect parental rights over the bodies of children, especially girls, assuming their vulnerability while rolling back the power of the medical profession within the private realm of the family.

This chapter begins by briefly outlining the course of Gillick’s challenge to the provision of contraceptive services to under-sixteens between 1979 and 1986. This highlights the marked differences between the terms of the debate set by Gillick, the press, and sympathetic parliamentarians, as well as the final legislative and legal outcomes of the case. Through this we see, ironically, the absence of the ‘Gillick competent child’ within Gillick’s own conceptualisation of the debate. In particular, the chapter examines the differing narratives and characters mobilised in the debate across a variety of venues, taking particular note of how children were portrayed as variously at risk of over-sexualisation, teenage pregnancy, incest, and suicide. The chapter then examines Just Seventeen’s response to the health needs of its adolescent readers under these challenging circumstances. This is achieved by exploring how Just Seventeen discussed adolescent health rights, particularly female reproductive health, between 1983 and 1986 in response to Gillick. Particular attention is paid to the narratives and characters deployed to give weight to arguments constructing teenage girls as competent consumers of contraceptive interventions provided, as was their right, by the NHS.

‘[…] what is at issue here is the usurpation by professional men of the traditional rights of parents’: Gillick’s challenge to medical authority, 1979–86

In theory, access to contraceptive healthcare through the NHS became available to all who needed it on 1 April 1974, when FPA-maintained clinics were absorbed into the health service as part of the 1973 NHS Reorganisation Act.15 Accompanying this reform was a Department of Health and Social Security (DHSS) memorandum clarifying the legality of advising those below the age of sixteen on contraceptive matters, with confidentiality emphasised.16 In 1978, with much media interest, the government began funding dedicated Youth Advisory Services.17 Access to, and education about, these services remained patchy, and condoms remained unfunded by the NHS, regardless of patients’ age or marital status.18 Regardless, these changes demonstrated a level of government commitment to contraception at a time when battles were even fought over the use of the word ‘contraceptive’ in advertising which would appear in public spaces.19

In 1982, after many years of gathering support, sending letters, and writing petitions, the devout Catholic mother of ten Victoria Gillick took West Norfolk and Wisbech Area Health Authority (AHA) to court for refusing to assure her that they would never provide contraceptive advice or technologies to her daughters without her consent while they were below the age of sixteen.20 While the choice to provide or refuse contraceptive advice or technologies lay in the hands of individual doctors, protected by their right to conscientious objection, a key 1980 DHSS memorandum advised doctors that while ideally parents should be informed, under-sixteens could receive such healthcare without parental knowledge or consent.21 The memorandum specifically emphasised the necessity of preventing unwanted pregnancies and sexually transmitted diseases in the under-sixteens, and the lawfulness of the provision of contraceptives to those in need but below the age of heterosexual consent. The case Gillick brought against her AHA in 1982 was broadly argued on two counts: firstly, that the provision of contraceptive advice and medicine to those below the age of consent was unlawful because by doing so doctors were causing or encouraging illegal sexual intercourse; and secondly, that the provision of advice and contraception to under-sixteens without parental consent contravened parental rights. At their heart, Gillick’s challenges articulated her belief in the primacy of parental authority over children, ‘her duty as a mother to the exclusion of any other person’, the innate biological and God-given suitability of a mother as final arbiter over her daughter’s vulnerable body, and the blasphemous nature of extramarital sex.22 Thus in challenging medical authority she was exercising her ‘fundamental right to concern herself with the moral upbringing of her children and […] right to rebuke interference’.23 Although the outcome of Gillick’s challenge created the medical and legal label for children with the capacity to consent, these children with ‘Gillick competence’ played no part in her arguments or the narratives she deployed to support them. Instead her battle was about a mother protecting her children, and her parental rights, from an overreaching state and the incursion of dangerous doctors bent on profiteering from the sexualisation of minors.24 Moreover, while some doctors expressed concern at the threat Gillick’s challenge posed to children’s rights and general access to NHS healthcare,25 the dominating narratives among the press and politicians were of an ‘epidemic’ of medically condoned ‘childhood sex’ or preventable teenage pregnancies.26

Gillick’s case was heard and dismissed by Mr Justice Woolf in July 1983. He argued that parents’ interests ‘are more accurately described as responsibilities or duties’ and assessed that there had been no transgression of the 1967 Sexual Offences Act by medical professionals.27 Or as the Daily Express put it,

Mother of ten, Mrs Victoria Gillick, wept in court yesterday, when a judge ruled she did not have the right to know if a doctor was putting her under-age daughters on the Pill.28

In an oft-quoted 1984 High Court statement in explanation of his position, Woolf emphasised the agency of the child rather than the parent, and began to define what would later be known as ‘Gillick competence’. He explained:

whether or not a child is capable of giving the necessary consent will depend on the child’s maturity and understanding and the nature of the consent required. The child must be capable of making a reasonable assessment of the advantages and disadvantages of the treatment proposed […]29

The assessment of a child’s competence thus remained within the purview of the clinical judgement of a doctor, not the opinion of a parent.

Woolf’s judgement in favour of the AHA was however reversed by the Court of Appeal on 20 December 1984, when the 1980 memorandum was judged to be ‘contrary to law’.30 This 1980 memorandum was in fact a softened version of a 1974 memorandum, altered after a great deal of lobbying and some Conservative pre-election pledges, to include more emphasis on the requirement of doctors to involve parents in their children’s contraceptive decisions as far as possible.31 Despite these earlier changes, the three judges involved in the appeal ruling of 1984 declared the memorandum in contravention of the law, as Lord Parker explained:

a girl under 16 can give no valid consent to anything in the areas under consideration, which apart from consent will constitute an assault whether civil or criminal and can impose no valid prohibition on a doctor against seeking parental consent. […] any doctor who advises a girl under 16 as to contraceptive steps to be taken or affords contraceptive or abortion treatment to such girl, without the knowledge and consent of the parent, save in emergencies, […] infringes the legal rights of the parent or guardian. Save in an emergency his proper course is to seek parental consent or apply to the Court.32

Gillick celebrated her appeal court victory in The Times, declaring it ‘the best possible Christmas present’.33 Elsewhere, newspapers dramatically reported the widespread alarm of sexual health educators and medical practitioners, who feared that the ban on contraceptive advice and technology for under-sixteens ‘could be tragic’, possibly leading to ‘more unwanted pregnancies, abandoned babies, late abortions and sexually transmitted diseases […] injury or death from self-induced abortions’.34

Gillick was able to enjoy her victory for only ten months. The House of Lords overturned her appeal in October 1985, reversing the changes to teenage access to healthcare she had effected, but ensuring her name would thereafter be associated with children’s ability to give consent to medical treatment or legal assistance below the age of (heterosexual) consent.35 Lord Scarman ruled that

parental right yields to the child’s right to make his own decisions when he reaches a sufficient understanding and intelligence to be capable of making up his own mind on the matter requiring decision.36

Prompted by Gillick’s challenge, the reinstated 1980 memorandum was reviewed and revised by the DHSS in 1986, with even greater emphasis placed on seeking parental consent for treatment of under-sixteens by doctors. While Gillick would claim some victory in these revisions, the 1985 ruling ultimately returned confidential contraceptive access to those below the age of consent.37

If we measure Gillick’s challenge by its outcomes, parental rights, medical authority, and children’s capacity were tested, confirmed, and redefined. Firstly, ‘parental rights’ were defined as duties to children, rather than rights over them; secondly, children with the capacity to comprehend and weigh decisions were granted a limited form of the patients’ rights to treatment and confidentiality afforded to adults; and thirdly, doctors’ authority to assess who had this (Gillick) competence, and their consequent duties to them, was confirmed in law and policy. Weighty though these definitions might be within medical ethics and jurisprudence, the Gillick case rendered few real changes in practice, generating a legal and medical label for the competent child under sixteen without granting many new rights or protections to children writ large. Rather it legalised existing common practice and protected medical practitioners in the process. Moreover, while the definitions which emerged as a result of the Gillick case are now applied internationally across genders and within legal and medical settings, the case, its narratives, and its players were originally much more strictly focused on girls and the contraceptive pill.

Writing with palpable indignation in 1985, Gillick reflected on the parallel media trials which followed her case through the court. Her argument that children needed to be protected by parents was met by the counter-argument that they needed to be protected from parents.

Every radio, television or newspaper article which attempted to ‘investigate’ the matter, drew upon the experience of doctors, sex councillors, gynaecologists and children, and paraded them before us, replete with all their grizzly tales of abortions, near deaths, incestuous pregnancies and suicides, maniacal fathers and feckless mothers, infections, cancers, infertility; the imposition of religious morality upon private sexual freedoms, and all the rest […]38

Her observation that the papers were ‘replete with all their grizzly tales’ bears scrutiny. Rather than arguing for confidential access to contraception as a necessary aspect of children’s rights as patients within the NHS, those opposed to Gillick’s cause instead provided readers with a stream of examples of vulnerable girls failed by their parents and the state. The ‘Gillick competent’ child that emerged from the case was largely unheard in an adult media which instead charted teenage suicides, pregnancies, and abuse, emphasising that without a protective doctor, vulnerable girls were at the inexpert and potentially lethal mercy of parents.

Teenage magazines, while offering readers a similar level of drama, tended to take a rather different tack. Just Seventeen mixed factual content on sexual health with reports on the case and its effects on frustrated teenagers whose attempts to responsibly guard their health were thwarted by legislation which underestimated their abilities. The Gillick case ironically presented a renewed opportunity to discuss sex and sexual health. Health columns and problem-page letters, already an enticing mix of titillating knowledge, schadenfreude, and melodrama, were lent a frisson of rebelliousness as magazines laid bare exactly the kind of knowledge Victoria Gillick hoped to have forbidden.

‘I am under 16 and pregnant’: health as crisis and empowerment in Just Seventeen

Just Seventeen’s first issue was given away free in the bestselling pop-music magazine Smash Hits on 13 October 1983, when it was advertised as the magazine ‘with girl readers of Smash Hits in mind’.39 Its editorial director, David Hepworth, later explained that the team behind Just Seventeen had aimed to create ‘something more grown up’ and ‘more sophisticated than the titles that were traditionally bought by teenage girls’.40 These aims were outlined in a lengthy mission statement on the contents page of the first issue which explained that this self-appointed ‘girls’ magazine for the 80’s’ saw teenagers as capable and hungry for ‘information’:

Some people think they can tell you what to wear, who to like, how to behave, what’s best for you. We reckon you can make your own mind up. What you need is information.41

By emphasising that teenage empowerment was reliant on information, Just Seventeen, as an information provider, presented itself as indispensable to successful teenage (girl) citizenship. Just Seventeen derided Gillick’s attempts to restrict access to contraception in part because her objections presented an antithesis to this ideology of information provision and consumption, offering no vision of empowered girlhood, no space for Just Seventeen’s knowledge-hungry audience.

While Just Seventeen’s introductory statement did not articulate an explicit ideological position on sex or health, in championing self-knowledge and individualism rather than specific moral ideals, its pages presented a variety of sexual identities and behaviours as socially acceptable. Some of these forms of subjectivity were marked by a knowing, if not actively pursued, sexuality. By blocking access to information and healthcare, Gillick disrupted this self-actualising narrative propagated by magazines like Just Seventeen. Her pillorying in the teenage press was both inevitable and deeply salient to an audience accustomed to consuming health information couched in the chatty rebellious tones of teenage magazines.

Drawing on the increasingly popular rhetoric of patient, citizen, and consumer rights within the NHS,42 Just Seventeen presented health rights and sexual health as entwined issues throughout the 1980s, with discussions of health and teenage rights framed by access issues in relation to sex education, contraception, and abortion particularly. These issues were occasionally addressed by discussing evolving government policy directly (such as through Gillick and, later, Section 28), but more often through the narratives of individual teenage girls’ experiences.43 Even in those articles where ‘the facts of life’ were presented and the consequences rendered by the laws which governed teenage experience were explicated, the prose addressed the reader through use of ‘you’ and ‘your’, and referred to the testimony of teenagers to create a sense of immediacy and authenticity. For the most part, these sexual health narratives encouraged the delayed onset of first sex, the avoidance of early pregnancy, and a degree of personal responsibility in all things relating to sexual health. Teenagers were thus largely addressed as individuals who had a right to (consume) knowledge, and a duty to themselves and their futures, to exercise this knowledge responsibly. However, the magazines also emphasised that the efforts of teenage girls to protect and empower themselves were stymied by limited access to sexual health knowledge, difficulties accessing the services they were entitled to, and the burden of contraceptive responsibility placed on them by patriarchal gender politics. By consistently identifying the political alongside the personal, Just Seventeen deftly expanded narrative focus from the responsibilities of the individual for their sexual health and healthy citizenship, to the difficulties experienced by the collective in exercising these rights as patients, consumers, citizens, and teenage girls. This plurality was made possible by the discursive nature of magazines as texts. Each edition of Just Seventeen offered a wide variety of voices and ideas, with readers’ letters to and from agony aunts, quizzes, articles, and advertisements creating a cacophony of voices which allowed the magazine to occupy multiple ideological positions simultaneously, representing multiple versions of healthy teenage femininity to its audience.

For example, in December 1983, a few months after Gillick’s first failed attempt to block contraceptive access to under-sixteens, Just Seventeen’s regular ‘Facts of Life’ health feature offered the following discussion of teenage pregnancy:

You need your parents’ permission to get married or leave home before you are 18 – so some girls force the issue by getting pregnant. […] some of these pregnancies are deliberate: some are accidental and happen because the couple believe myths […] Quite a few happen because no-one has bothered to tell you what actually causes pregnancy!44

In just one short paragraph, the causes of teenage pregnancy are blamed on ‘some girls’ seeking to become pregnant, myth-believing couples, and eventually the nameless authoritative knowing ‘no-one’, who has failed to explain the cause of pregnancy to ‘you’ – the general reader of Just Seventeen. While the article left open the possibility of teenagers exercising their agency to have planned pregnancies, the remainder of the article concentrated on furnishing the readers with the knowledge to prevent unwanted pregnancies. It continued:

There are two ways to avoid getting pregnant. One is very simple and is probably the best method for young people. DON’T MAKE LOVE!

[…] the other way to prevent pregnancy? You can use a method of birth control.45

The feature then offered a detailed discussion of multiple methods of birth control, before explaining:

All these methods are free and can be given to you by your family doctor (except the sheath) or by your local family planning clinic or Brook Advisory Centre. […] Whatever your age nobody need know you have asked for help or advice.

The reassurance offered here, that access was easy and confidentiality sacrosanct, was then somewhat diluted by the following caveats:

But if you are under 16, since your boyfriend is breaking the law by having sex with you, a doctor may refuse to prescribe contraception at all, or until he has permission from your parents. And if you are young, the doctor would be quite right to ask you to tell them what you are doing.46

Thus teenagers were encouraged to exercise their rights as patients within the NHS – to treatment and confidentiality – but discouraged from engaging in the illegal act of under-age sex which rendered treatment necessary. As was typical of Just Seventeen’s discussions of under-age sex, this feature closely echoed the advice issued in the 1980 DHSS memorandum to which Gillick objected. This warning against under-age sex, the encouragement to tell parents, and also the giving of information and reassurance around contraception, access, and confidentiality were repeated across Just Seventeen whenever the subject of under-age sex came up – which it did frequently. For example, in response to an under-age reader’s letter seeking advice on access to contraception, the agony aunt Melanie McFadyean replied:

I must point out to you that it is in fact against the law for a girl to have sex before she’s 16. It is not however, against the law for a girl under 16 to get contraception which is freely available on the National Health from your doctor or local family planning clinic.47

This sort of response was so typical of Just Seventeen throughout the 1980s and 1990s that its contraceptive content occasionally invited critique from readers and readers’ parents, with the magazine happy to publish dissenting voices in order to respond by presenting its ideological position on the matter. Indeed, as Gillick’s case made its way through the courts, discussions of contraception which included opposing views featured more frequently, schooling readers in arguments in defence of their health rights. For example, in the same 1984 issue of Just Seventeen which included the lengthy ‘Facts of Life’ feature ‘Dealing with your Doctor’ (which is quoted above), the problem page included a letter from ‘Disgusted Just Seventeen Reader’, which offered the following diatribe:

After reading your advice page I was disgusted to read that girls aged between 13 and 16 were writing to you for advice on sex. Don’t you think girls of that age should be enjoying themselves rather than worrying about what contraceptives to use? Most girls that age don’t understand the situation they could find themselves in. Teenage boys aren’t likely to stay around for long when they’ve got what they want. The poor girl is left alone with the chances of an unwanted pregnancy.48

By publishing a critique of teenage access to contraception predicated upon the idea of teenage girls as vulnerable and naive, and boys as irresponsible predators, Just Seventeen was able to engage with aspects of the debate emerging around Gillick’s challenge selectively, avoiding more contentious and capacious questions of morality or bodily autonomy. While McFadyean conceded that ‘Sexual relationships are complicated’ – a point often made in the magazine to try to encourage a delayed onset of first sex – she also argued:

But who are you or I to say these girls can’t cope or aren’t enjoying themselves with boys? Some teenage boys aren’t only interested in ‘one thing’ – your attitude is a bit cynical.49

By questioning the authority of ‘Disgusted’ to make decisions about the lives and experiences of adolescents, the response firmly placed the power to make decisions about sex and contraception into the hands of teenage girls and boys. Though McFadyean’s reply ended by emphasising teenage girls’ position as contraceptors – ‘The only thing I can tell girls to do is to protect themselves’ – the defence of teenage boys here is significant.50 While Just Seventeen frequently discussed the ‘double standard’ – wherein girls were expected to be virgins, and boys lotharios – and warned girls that sexism would lead them to carry the majority of the contraceptive burden,51 it also entertained the possibility of teenage boys as respectful lovers and friends. This more sympathetic and egalitarian approach to teenage sexuality and emotions was typical of both the new magazines of the 1980s and the sexual health educators who served the young through charities like Brook and the FPA.52 For these adult sexual health educators, teenagers not only had rights to contraception in law, but also had meaningful relationships deserving of respect. Ensuring teenage access to contraception through the NHS was not just about avoiding teenage pregnancy, then; it was also about respecting teenage relationships, fighting gendered inequality, and preparing teenagers for the sex they would have, regardless of adult disapproval. Through McFadyean’s reply, the magazine was able to position itself as a sympathetic defender of teenage rights while implying that contraceptive use was part of demonstrating you could ‘cope’ as a teenage girl.

Teenage healthy citizenship through the NHS

While teenage health rights were most frequently framed through contraceptive access, Just Seventeen also addressed health holistically. Articles and problem page letters on weight, acne, and general gynaecological health peppered the magazines across the 1980s,53 with suggestions that teenagers see their general practitioners (GPs) frequently offered in answer to any health-related query. Teenagers often wrote in asking about specific access needs, from locating sexual health clinics to age limits on plastic surgery or wishing to change doctors because their GP was a friend of the family. These broader discussions encouraged teenagers to seek and exercise a diverse range of health rights, not limited to the bedroom. This more holistic approach destigmatised sexual health seeking behaviours, while the consistent matter-of-fact tone taken in all health discussions allowed Just Seventeen to unobtrusively avoid moralistic debates around abortion, instead presenting it as an uncontentious medical procedure that was a matter of personal choice.

Knowing about and using the NHS was configured in Just Seventeen as a fundamental aspect of being a mature teenager. While the magazine was careful to avoid actually encouraging teenagers to act on the sexual knowledge offered in its pages, discussions of the NHS tended to be more didactic in tone, encouraging teenagers to seek health through accessing services, choosing their doctors, and understanding consent. As the opening paragraph of the ‘Dealing with your Doctor’ edition of the regular ‘Facts of Life’ feature explained:

We pay £18 per family each week for the National Health Service – so it is hardly accurate to call our medical services ‘free’. But the reason our health service is funded in this way is so nobody will ever put off seeking help with an illness because of expense. The only problem with not paying for a service as you need it is that many people come to think of it as a charity and don’t like to ask for what they are entitled. To help you look after yourself, here is a brief guide to your rights under the National Health.54

Here the magazine drew on a rhetoric of ‘patients’ rights’, framed in part as consumer rights, which had emerged in the 1970s and 1980s alongside Conservative reforms to the health system and the emphasis of patients’ rights groups on individual experiences.55 By framing the upkeep of the NHS as a familial rather than individual expense, Just Seventeen created a narrative of entitlement to services, partially predicated on payment, which could include even young teenagers, instilling the idea that health rights were not dependent on age or employment status. Instead, teenagers were constructed by the magazine as citizens and consumers who could expect to access the health provisions offered by the NHS for ‘free’. In 1983 only 4 per cent of those aged sixteen and older had private medical insurance,56 so reassuring teenagers that they had a right to ‘free’ treatment in both the present and future would have resonated with the majority of readers. As in other health features, contraception and pregnancy were deployed in the article as the key narrative for explaining confidentiality and consent.

if you ask your doctor for contraception your doctor can refuse you but unless you give permission, shouldn’t tell your parents. If you are pregnant and your parents insist on an abortion ‘to save their faces’ or that you keep the baby ‘to teach you a lesson’ your doctor can listen to what you want and do what is medically and emotionally right for you.57

Here the narrative of a forced pregnancy or abortion was used, with the NHS doctor positioned as fighting alongside the teenage reader of Just Seventeen to defend reproductive rights as an aspect of healthcare. This narrative of unsympathetic parents and saviour doctors appeared often in the problem page letters and feature-length articles of Just Seventeen,58 and would have been familiar to even casual readers of teenage magazines because it also circulated persistently in the adult press coverage of Gillick’s case.59 Accessing the pill, having an abortion, or keeping a pregnancy against parental wishes required knowledge of rights and trust between teenage patients and the NHS. This trust was fostered in teenage magazines by broadening the discussion of health rights beyond reproductive healthcare. The ‘Dealing with your Doctor: Facts of Life’ feature went on to explain the intricacies of choosing a doctor, paying prescription charges, confidentiality, and giving consent:

At 16, you can choose your own doctor in your area from a main Post Office or from the Family Practitioner Committee.


Any doctor has an obligation to see and treat you if you are ill enough to be in danger, but doesn’t have to take you on as a permanent patient. If you can’t find a practice to take you, contact the F.P.C. because they have an obligation to find you one.

You can change your doctor at any time and you don’t have to give a reason.


Doctors must ‘render to their patients necessary and appropriate personal medical services’. This means they must see you themselves or arrange for a deputy […] It doesn’t mean they are gods and can always cure you!


All necessary medicines are paid for by the N.H.S. and you usually only have to pay a prescription fee […] In reality, the price of most items is a lot more than you give each time. […] some medicines are as much as £50 a bottle! […] Prescriptions are absolutely free if you’re under 16, retired, pregnant, have a child under one year, have a low income […] Birth control is free to all.

[...] if you visit the Venereal or Sexually Transmitted Disease Clinic – also called a ‘Special’ Clinic – or a Family Planning Clinic or a Well Woman Clinic. All these will see you without a referral and keep your visit private if you don’t want your doctor to know.

While you are in hospital all treatment and medicines are free […] you can question any procedures and make up your mind whether or not to have it – and refuse if you like.60

When Gillick won her appeal, the prior holistic positioning of sexual health as part of general health allowed teenage magazines to critique Gillick’s attack on contraceptive access as a broader attack on teenage health rights within the NHS. Just Seventeen had spent nearly two years explaining to teenagers that they had a right to free confidential treatment within the NHS and a responsibility to themselves to seek it. Just Seventeen had been successfully selling magazines rich in health information, using contraceptive services as a shorthand for discussing wider teenage health rights; its readers were primed to receive its rebuttal to Gillick’s challenge.

‘The Pill: Whose Right to Choose?’: teenage magazines respond to Gillick directly

On 24 January 1985, just over a month after Gillick won her appeal, Just Seventeen ran a special discussion piece titled ‘The Pill: Whose Right to Choose?’61 It included testimony from young people who had sought contraceptive services in the past or who wished to defend their right to confidentiality in the future.

While the article’s introduction announced that ‘Family planning and children’s organisations are worried that there will be an increase in the number of pregnancies and abortions involving girls under the age of 16’, the piece also drew on the words and experiences of teenagers. Indeed, the article is framed by the words of Gina, aged fifteen, who declared, ‘If it hadn’t been for the doctor I think I would have killed myself.’62 This outlining of contentious issues affecting teenagers through personal testimony was typical of Just Seventeen’s handling of these sorts of subjects, and Gina’s mention of suicide was in keeping with the fraught tone of media coverage of the Gillick case. Indeed, the press widely alleged that Gillick’s win had contributed to the deaths of two girls, aged twelve and fourteen, who had died by suicide upon realising they would not be able to access contraception without parental consent.63 Alongside Gina’s testimony, a largely factual explanation of the Gillick case, and a section on ‘EMERGENCY HELP’, the feature drew on the opinions of six other teenagers. The three boys and three girls offered a variety of voices, in support of and opposition to Gillick, with small photographic portraits alongside their opinions lending authenticity to each differing view. Significantly, the large ‘EMERGENCY HELP’ section of the article explained what newspapers called the ‘legal loophole’ that pro-contraception medical practitioners intended to exploit in order to continue their work. It explained:

If you are under 16, and feel you need help and advice about contraception – and you can’t talk to your parents – you can still go to your doctor, a family planning clinic or a Brook Advisory Centre. They will NOT repeat any of your discussion with your parents. This is because the Court of Appeal said that under 16s could still be given advice and contraception ‘in an emergency’, and at the moment the DHSS says the term ‘emergency’ can be defined fairly openly.64

The emergencies stipulated in the article included cases of incest and homelessness, but also, as far as the FPA was concerned, ‘a girl under 16 having sex without contraception’.65 Unfortunately for the FPA, even with this loophole, the charity was forced to withdraw two sexual health education pamphlets from circulation after Gillick won her appeal, and to advise its councillors to solicit parental consent if at all possible.66 The British Medical Association (BMA) and General Medical Council (GMC), while both voicing vocal opposition to the Gillick ruling, advised similar caution, leading some doctors who were unable to gain parental consent for teenagers in need of contraceptive services to turn them away. As 1985 progressed, press interest in these would-be pill-users grew. Sexual health providers warned of an impending rise in teenage pregnancies and abortions, fanning interest, but it was the BMA’s claim that two teenagers had taken their own lives when unable to access contraception which grabbed the most headlines.67 Gillick began to receive death threats, and small crowds gathered shouting ‘murderer’ when she appeared in public.68

Teenagers responded to this more pessimistic climate directly, writing letters to express opinions and ask questions. Caz wrote in anger to Just Seventeen to explain ‘how annoyed I am at the irresponsibility of Parliament and some doctors, especially after hearing about the 15 year old Reading girl who has become pregnant after not being allowed the Pill’69 – but for the most part readers wrote in fear and confusion, no longer able to trust their doctors to keep their confidence and unsure of their rights within the NHS.

In March 1985, as the furore around the Gillick ruling rumbled on, Just Seventeen published a much more pessimistic assessment of the effects of Gillick’s appeal court win on teenage access to NHS services and rights in general.

Did you realise that this decision has made it illegal for a doctor to give any medical treatment without asking permission?

Don’t bother to drop in to the surgery on your way home from school to have a verruca removed, that cut dressed or your waxy ears syringed. Not, that is, without dad or mum, or a letter. Because if your doctor touches you, he or she is breaking the law.

[…] Before the Gillick ruling, you could go and talk in private with your doctor and ask for help if a member of your family was sexually abusing you. […] Now, if you have any problems at home and want help to sort them out, your doctor or any other adult may have to send you away until parents can be brought in on the discussion too.70

The impact of Gillick on teenage health rights, while technically reversed when the Law Lords overturned her appeal in October 1985, remained evident in the confusion her case wrought over how under-sixteens could access contraceptive services. For example, despite the 1980 memorandum being reinstated (pending DHSS review) in 1986, the GMC released guidance that doctors could breach the confidentiality of patients under sixteen who were not ‘Gillick competent’ but sought treatment.71 This guidance was immediately met with outcry from the BMA and other medical and legal bodies interested in children’s rights who felt it misunderstood the Law Lords’ ruling.72 While this GMC guidance was subsequently withdrawn, it was reported with concern in the teenage press,73 and it demonstrates the boundaries blurred by the Gillick case even after she lost. Elsewhere, alongside accusations of causing teenage suicides,74 the apparent rise in teenage pregnancies was laid at Gillick’s feet for some years after her case concluded.75


Owing in part to the difference between the aims and the outcomes of this case, the passage of Gillick’s challenge through the judicial courts, and indeed the court of the media created more than a new label for a specific kind of child: it also created a space of confusion and debate about the contraceptive rights of the child and the claims they could make on the NHS. In the pages of Just Seventeen, growing up well meant knowing about (and avoiding) sex, how to access health services, accessing them promptly when required, and having the knowledge to make contraceptive choices. Indeed, the magazine deployed discussions of Victoria Gillick’s challenge to teenage autonomy opportunistically and with a degree of drama, promoting knowledge of adolescent rights within the health service as one aspect of the exciting empowered teenage femininities it sold.

Through discussions of contraceptive access, teenage girls were introduced to their wider health rights and were encouraged as both individuals and members of a collective to access the NHS and guard their health. Teenagers were asked to invest ideologically in healthy citizenship (and so in the NHS) as an ideal of teenage femininity, taught to expect confidential treatment which was free at the point of use, and prepared for a future when they would contribute to the upkeep of the NHS, both through ongoing personal healthful behaviours and financially as earning citizens. This healthy citizenship was entwined with a kind of future sexual citizenship which anticipated contraception use, delayed first sex, and disease prevention behaviours. By championing this configuration of teenage citizenship, Just Seventeen was able to position Gillick’s objection to teenage contraceptive access as not just anti-adolescent rights, but also anti-health, in contravention of the principles of the NHS and threating to its survival as an institution.

Moreover, in demonstrating that Gillick threatened general teenage access to healthcare, rather than merely access to the pill, Just Seventeen mobilised the idea that teenagers’ access to healthy citizenship writ large was being threatened. The NHS here had a talismanic quality, standing in for a narrative of individual responsibility which worked towards the good of a greater community of responsible healthy teenage citizens, who would grow up well and pay their dues.


1 While teenage girls’ magazines like Just Seventeen anticipated an audience mainly made up of cis heterosexual adolescent girls, they also enjoyed a small but significant number of queer and cis boy readers. Articles aimed at enticing audiences beyond the cis girl readership appeared with increasing frequency during the 1980s and 1990s, including a section specifically aimed at boy readers in the 1990s.
2 Here I refer to the age of consent between cis partners of differing genders. The age of consent between cis men was 21 until 1994 when it lowered to 18. The age of consent between cis women was set at 16 in the Sexual Offences (Amendment) Act 2000, which also brought consent between cis men in line with heterosexual consent.
3 Hannah J. Elizabeth, ‘[Re]inventing Childhood in the Age of AIDS: The Representation of HIV Positive Identities to Children and Adolescents in Britain, 1983–1997’ (unpublished PhD thesis, University of Manchester, 2016), pp. 111–49.
4 Kaye Wellings, The Role of Teenage Magazines in the Sexual Health of Young People (London School of Hygiene and Tropical Medicine: Department of Public Health and Policy, November 1996), pp. 4–5.
5 Ibid., p. 4.
6 Adrian Bingham, ‘Newspaper Problem Pages and British Sexual Culture since 1918’, Media History, vol. 18, no. 1 (2012), pp. 51–63, at p. 53.
7 Ann Blair and Daniel Monk, ‘Sex Education and the Law in England and Wales: The Importance of Legal Narratives’, in Lutz D. H. Sauerteig and Roger Davidson (eds), Shaping Sexual Knowledge: A Cultural History of Sex Education in Twentieth Century Europe (London: Routledge, 2009), pp. 37–51, at 38–9.
8 Wellings, The Role of Teenage Magazines, p. 4; E. Davies, ‘An Examination of Health Education in Teenage Magazines’, Health Education Journal, vol. 45, no. 2 (1986), pp. 86–91; S. Davis and M. Harris, ‘Sexual Knowledge, Sexual Interests and Sources of Sexual Information of Rural and Urban Adolescents from Three Different Cultures’, Adolescence, vol. 17 (1982), pp. 471–92.
9 Hannah J. Elizabeth, ‘Love Carefully and without “Over-Bearing Fears”: The Persuasive Power of Authenticity in Late 1980s British AIDS Education Material for Adolescents’, Social History of Medicine, vol. 34, no. 4 (November 2021), pp. 1317–42, https://doi.org/10.1093/shm/hkaa034.
10 Elizabeth, ‘[Re]inventing Childhood’, pp. 111–49.
11 Angela McRobbie, Feminism and Youth Culture: From ‘Jackie’ to ‘Just Seventeen’ (London: Macmillan Education Limited, 1991), pp. 83–91.
12 Frank Mort, Cultures of Consumption: Masculinities and Social Space in Late Twentieth-Century Britain (London: Routledge, 1996), pp. 1–12; Ben Mechen, ‘“Closer Together”: Durex Condoms and Contraceptive Consumerism in 1970s Britain’, in Jennifer Evans and Ciara Meehan (eds), Perceptions of Pregnancy from the Seventeenth to the Twentieth Century, Genders and Sexualities in History (Cham: Springer International Publishing, 2017), pp. 213–36; Sarah Kenny, ‘Unspectacular Youth? Evening Leisure Space and Youth Culture in Sheffield, c. 1960–c. 1989’, unpublished PhD thesis, University of Sheffield, 2017.
13 Elizabeth, ‘[Re]inventing Childhood’, pp. 111–49; Hannah J. Elizabeth, ‘Getting around the Rules of Sex Education’, Wellcome Collection, 7 June 2018, https://wellcomecollection.org/articles/WxZnZyQAAPoF1PS8 (accessed 10 January 2019).
14 ‘Facts of Life: Dealing with your Doctor’, Just Seventeen, 9 February 1984, pp. 20–1.
15 Jesse Olszynko-Gryn and Caroline Rusterholz, ‘Reproductive Politics in Twentieth-Century France and Britain’, Medical History, vol. 63, no. 2 (2019), pp. 127–8; National Health Service Reorganisation Act (1973). The quotation in the subheading above is from ‘Doctors and Children’, Daily Telegraph, 23 June 1983, p. 18.
16 Department of Health and Social Security, ‘Family Planning Service Memorandum of Guidance’, Circular HSC(IS)32, May 1974.
17 For a discussion of the FPA’s and Brook’s relationship with the DHSS and health policy in the 1980s see Elizabeth, ‘Love Carefully’.
18 Many FPA and Brook centres did provide free condoms to service users, but at a cost to the charities rather than the NHS. Lindsay Mackie, ‘“More Cash” Call by Sex Advice Centre’, Guardian, 13 June 1977, p. 4.
19 Katharine Whitehorn, ‘Such a Fuss about Contraceptive Ads’, Observer, 8 January 1978, p. 23.
21 Department of Health and Social Security, Circular, HN (80) 46, December 1980.
22 David Walker, ‘Giving the Pill to Under-Age Girls Nearly a Crime, QC Says’, The Times, 19 July 1983, p. 3.
23 Ibid.
24 Victoria Gillick, ‘Prescriptions for Young’, Daily Telegraph, 31 January 1984, p. 14.
25 Nicholas Timmins, ‘All Children’s Treatment Threatened by Pill Challenge, Doctors Say’, The Times, 2 December 1983, p. 3.
26 Adrian Rogers, ‘Let’s End this Epidemic of Childhood Sex: Dr Adrian Rogers Discusses the Case against Allowing Children Intercourse’, Daily Telegraph, 13 January 1983, p. 16; David Hughes, ‘Under-16 Pill Ban “Could Be Tragic”’, Daily Mail, 29 January 1985, p. 9.
27 Lewis and Cannell, ‘The Politics of Motherhood’, p. 327.
28 Daily Express, 27 July 1983, quoted in Victoria Gillick, Dear Mrs Gillick: The Public Respond (Basingstoke: Marshall Pickering, 1985), p. 9.
29 Wellcome Archive, London, SA/FPA/C/E/15/11, Children’s Legal Centre, ‘Landmark Decision for Children’s Rights’, 1985, p. 3; Gillick v. West Norfolk and Wisbech Area Health Authority (1984) 1 All ER 365, cited in ibid., p. 5.
30 Lewis and Cannell, ‘The Politics of Motherhood’, p. 324; Wellcome Archive, SA/FPA/C/E/15/11, Children’s Legal Centre, ‘Young People’s Rights and the Gillick Case’, 1985, p. 3.
31 John Harrison, ‘Doctors ‘should Tell Parents Girl is on the Pill”’, Daily Mail, 20 February 1980; Wellcome Archive, SA/FPA/C/B/3/12/1, Family Planning Association internal memorandum from Alistair Service to colleagues responding to changes in the 1974 memorandum, 21 February 1980.
32 Wellcome Archive, SA/FPA/C/E/15/11, Children’s Legal Centre, ‘Young People’s Rights and the Gillick Case’, 1985, p. 2; Gillick v. West Norfolk Area Health Authority (1985) 1 All ER 533, CA at 551.
33 Nicholas Timmins, ‘“The Best Possible Christmas Present”’, The Times, 21 December 1984, p. 1.
34 Hughes, ‘Under-16 Pill Ban “Could Be Tragic”’; Martin Wainwright, ‘Gillick Verdict Alarms Doctors’, Guardian, 21 December 1984, pp. 1–2.
35 Lewis and Cannell, ‘The Politics of Motherhood in the 1980s’, p. 322.
36 Jane Fortin, Children’s Rights and the Developing Law (Cambridge: Cambridge University Press, 2003), pp. 80–2.
37 Guttmacher Institute, ‘Girls under 16 Do Not Need Parental OK to Obtain Contraceptive Services, Says Britain’s Highest Court’, Family Planning Perspectives, vol. 17, no. 6 (1986), pp. 267–8.
38 Gillick, Dear Mrs Gillick, p. 120.
39 ‘For your Eyes Only’ (editorial), Just Seventeen, 13 October 1983, p. 3.
40 David Hepworth, interview with Hannah J. Elizabeth, 16 October 2013.
41 ‘For your Eyes Only’, p. 3.
43 Between 1988 and 2003 Section 28 of the Local Government Act 1988 prohibited the ‘promotion of homosexuality’ by local authorities in England and Wales. See Jackie Stacey, ‘Promoting Normality: Section 28 and the Regulation of Sexuality’, in Sarah Franklin, Celia Lury, and Jackie Stacey (eds), Off-Centre: Feminism and Cultural Studies (London: Harper Collins, 1991), pp. 284–304; Elizabeth, ‘Getting around the Rules’.
44 Gillian Martin, ‘Facts of Life: Couples’, Just Seventeen, 15 December 1983, pp. 13–14.
45 Ibid.
46 Ibid. (emphasis in original).
47 Melanie McFadyean, ‘Advice’, Just Seventeen, November 1983, p. 52.
48 ‘Disgusted Just Seventeen Reader’ to Melanie McFadyean, ‘Advice’, Just Seventeen, 9 February 1984, p. 37.
49 Ibid.
50 Ibid.
51 Suzie Hayman, ‘“What Boys Think” about Love, Sex and Birth Control’, Just Seventeen, 6 March 1985, p. 18; Melanie McFadyean, ‘Advice’, Just Seventeen, 6 March 1985, pp. 41–2; Melanie McFadyean, ‘Advice’, Just Seventeen, 12 June 1985, p. 43.
52 For a more extensive discussion on the use of love and authenticity to promote safer sex among teenagers see Elizabeth, ‘Love Carefully’ and Katherine Jones, ‘“Men Too”: Masculinities and Contraceptive Politics in Late Twentieth Century Britain’, Contemporary British History, vol. 34, no. 1 (June 2019), pp. 44–70, 10.1080/13619462.2019.1621170.
53 ‘Facts of Life: The Female Body’, Just Seventeen, 22 March 1984, p. 15.
54 ‘Facts of Life: Dealing with your Doctor’, Just Seventeen, 9 February 1984, p. 20.
55 Mold, ‘Patients’ Rights and the National Health Service in Britain’.
56 Office of Population Censuses and Surveys, General Household Survey 1983 (London: HMSO, 1983), p. 152.
57 ‘Facts of Life: Dealing with your Doctor’, p. 20.
58 Suzie Hayman, ‘Teenage Mothers’, Just Seventeen, 4 October 1984, pp. 20–1.
59 George Theiner, ‘How Mrs Gillick will Inflict Endless Misery on Teenagers’ (letter), Guardian, 27 December 1984, p. 10.
60 ‘Facts of Life: Dealing with your Doctor’, pp. 20–1. Emphasis in original.
61 Bridget Le Good, ‘The Pill: Whose Right to Choose?’, Just Seventeen, 24 January 1985, p. 20.
62 Ibid.
63 Wellcome Archive, SA/FPA/C/B/3/12/3, newspaper clipping: Charles Langley, ‘Tragedy of the No-Pill Girls’, Daily Star, 8 February 1985; Lynda Lee-Potter, ‘This is Why Mrs Gillick is Wrong’, Daily Mail, 13 February 1985, p. 7.
64 Le Good, ‘The Pill’.
65 Ibid.
66 Wellcome Archive, SA/FPA/C/E/15/11, Alistair Service, internal FPA memorandum responding to Gillick ruling, 23 January 1985, pp. 1–3; Wellcome Archive, Romie Goodchild, ‘FPA Press Release: Gillick Ruling: FPA Warns Minister of Disastrous Consequences’, 12 February 1985, p. 1; Andrea Viecht, ‘Sex Guides Withdrawn’, Guardian, 13 February 1985, p. 8.
67 Andrew Veitch, Medical Correspondent, ‘Courts “the Only Resort” for Girls Seeking Abortion’, Guardian, 21 May 1985, p. 4; Langley, ‘Tragedy of the No-Pill Girls’.
68 Gordon Greig, ‘Campaign of Hate against Pill Wife’, Daily Mail, 25 September 1985, p. 13.
69 Caz, ‘The Pillock – Sorry Gillick Ruling’, Just Seventeen, 12 June 1985, p. 29.
70 Suzie Hayman, ‘The Effects of the Gillick Case’, Just Seventeen, 20 March 1985, p. 61.
71 ‘Professional Confidence: Doctors Advised to Assess Child’s Maturity’, BMJ, 292:6519 (22 February 1986), pp. 570–1.
72 ‘From the Council: GMC Asked to Reconsider Advice on Confidentiality and the Under 16s’, BMJ, 292:6522 (15 March 1986), pp. 778–82; J. D. Havard, ‘Teenagers and Contraception’, BMJ, 292:6519 (22 February 1986), pp. 508–9.
73 Melanie McFadyean, ‘Contraception and Under-16s’, the Latest News’, Just Seventeen, 5 March 1986, p. 19.
74 Lee-Potter, ‘This is Why Mrs Gillick is Wrong’, p. 7.
75 Andrew Veltch, ‘Teenage Births Rose after Gillick Victory’, Guardian, 1 December 1986, p. 4.
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Posters, protests, and prescriptions

Cultural histories of the National Health Service in Britain

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