Response: ‘What is Transphobia?’ from Edinburgh University

We have become aware of an article on the University of Edinburgh’s official website in the Equality, Diversity and Inclusion section titled “What is transphobia?”. The article presents itself as an authoritative resource for students, and gives the impression that it is the settled, agreed position of the University. In fact it is a political piece, promoting highly contested ideological arguments as though they are undisputed facts. Many students and staff within the university do not share the views of the author and are concerned that one side of an ongoing public debate is being endorsed by the university. This has the potential to further escalate tensions on campus between those with differing viewpoints.

In a response to the Scotsman, the university stated:

“The web-page in question was designed as a resource to support students, inform discussion, and help promote a respectful, diverse and inclusive community.”

“Given the size of our community, it is inevitable that the ideas of different members will often and, quite naturally, conflict. We encourage members of our community to use their judgement and openly contest ideas that they oppose, and feel protected in doing so.”

Unfortunately, many students do not feel able to openly contest the opinions put forward within the article as a result of the intimidation targeted towards those who hold “gender critical” views. In 2019, Julie Bindel was assaulted on campus after giving a talk at a university event on sex and gender. Speakers for this event were described as having “a history of transphobia” in an email and blog published prior by the staff pride network. Many women on campus witness events like this and self-censor for fear of reprisal. By posting this article, and endorsing the views it expresses, the university makes it even less likely that women students and staff will feel protected when advocating for our legal rights.

XX are a feminist network, including students at the University of Edinburgh, who oppose these ideas.

This document opens by providing a definition of transphobia: “Transphobia is the hatred, fear, disbelief, or mistrust of trans and gender non-conforming people.” This definition is broad, stretching so far as to encompass belief. What does “disbelief” mean in this context? In the university’s Trans Inclusion Policy, students and staff are advised to “Think of the person as being the gender that they want you to think of them as.” Could not thinking of a person as their desired gender be considered “disbelief” and therefore constitute transphobia? It’s worrying that a university is stating how individuals ought to think in official policy. Section 12.4 of the university’s Student Code of Conduct describes “Conduct which unjustifiably infringes freedom of thought or expression whilst on University premises or engaged in University work, study or activity;” as examples of misconduct and yet it encourages this behaviour in its policy. The author of this article suggests the existence of three genders; many proponents for gender identity theory take this even further and argue for the existence of hundreds. These are contentious and unproven theories that are rejected by many in various fields from across the political spectrum. “Disbelief” is not evidence of prejudice, it’s evidence of freedom of thought and expression.

The author goes on to claim that there has been a “resurgence of transphobia” linked to government proposals to reform the Gender Recognition Act (GRA) but fails to mention the fact that these proposals were accompanied by consultations in which the public were invited to share their views. The proposed measures correctly identified as “self-declaration” would allow for individuals to change the sex on their birth certificate through an administrative process, removing the current requirement for a medical diagnosis and the oversight of a specialist panel. No clarity has been provided as to what rights are conferred by obtaining a Gender Recognition Certificate (GRC) and what the impact the ease of access provided by the removal of gatekeeping will be. The GRA describes the consequences of obtaining a GRC as the following:

“Once a full gender recognition certificate is issued to an applicant, the person’s gender becomes for all purposes the acquired gender, so that an applicant who was born a male would, in law, become a woman for all purposes.”

The Equality Act (2010) specifies exemptions where a person with the protected characteristic of “gender reassignment” can be excluded from single-sex spaces and services should it be deemed a “proportionate means of achieving a legitimate aim”. Women are frequently demonised as transphobic for pointing out that in some instances there are conflicts of rights arising from the two pieces of legislation, and for asking for those conflicts to be explored and resolved. In “What is Transphobia?”, there is a similar attempt to paint women’s arguments as simply “dogwhistles” for bigotry. These “reasonable concerns” (concerns over the collective redefinition of your social and legal category tend to be reasonable) are described by the author as “a way to limit the rights of and marginalise trans and non-binary people”. Here, the “right” to self-declaration is presupposed, while women’s boundaries are portrayed as hostile and women’s right to speak on issues affecting them is dismissed. Outside of the University, things have been changing, and women have been rightfully acknowledged as stakeholders in discussions surrounding gender recognition reform. For instance, the feminist scholars Professor Kathleen Stock OBE, Professor Rosa Freedman and Professor Alice Sullivan were invited to provide evidence to the Women and Equalities Committee (WEC) inquiry into the issues surrounding self-declaration.

The article then resorts to the trope that feminists are demonising trans people by “distorting statistics of male violence to imply it is a characteristic of trans women”. This argument was addressed by Dr Stock in her submission to WEC:

“Up until now, it has been uncontroversial that we exclude all males, including all the innocent ones and the majority of reasonable people, on the basis that we want to exclude a few malfeasant people. That has been perfectly well understood that it was never a character reference. It was never supposed to say that all males were bad because they clearly are not. Exactly the same logic applies with self ID and the thought about spaces. In other words, it is excluding the many innocents in order to focus on a few. There is no reason to think that, once you self-ID as a woman, you become less subject to the statistical generalisations that apply to the male sex. Having said that, you should look again at the evidence submitted in the last trans inquiry by the British Association of Gender Identity Specialists and the British Psychological Society, which are very trans-friendly organisations. I can check again and send it. They both say that, of course, there are circumstances where people will identify for malfeasant purposes. Of course there are; it is human nature. Of course that is not all trans people but equally it very strange to rule that out a priori. It is completely strange.”

The possibility that this system may be open to abuse cannot be ruled out and it’s important that any possible risks are assessed before proceeding. It’s more than likely that vulnerable women in rape shelters, hostels and prisons will not be in a position to bring forward test cases. When women do object to natal males in their spaces, James Morton, from the Scottish Trans Alliance, has argued that they should be “educated” into consenting.

Later in the WEC evidence session, Professor Freedman references a Swedish study that suggested transwomen exhibit a male pattern criminality. Dr Stock points out that this study only refers to those who have undergone medical and hormonal treatment — there is a lack of evidence surrounding the impact of self-declaration. In 2017, Fair Play for Women published a report, since confirmed by the Ministry of Justice, that revealed that 41% of trans prisoners were sex offenders, while 19% of all prisoners are serving time for a sexual offence. Presumably, these are the “distorted statistics” referred to in the article. These figures are not distorted, they are facts, and it’s intellectually dishonest to pretend otherwise. We cannot ignore statistical realities just because they are politically inconvenient. Admittedly, there are gaps in the evidence base, and this needs to be addressed. But reliable evidence can only be gathered if data on both sex (male/female, defined by biology) and gender reassignment (or identity) are collected. The obfuscation of language in the area, and reluctance on the part of organisations and institutions to insist that sex is dimorphic, fixed and immutable, present considerable obstacles for researchers wanting to gather, analyse and use data for the purposes of understanding the significance of sex and gender respectively on crime patterns.

Another key claim in the article is that “misinformation” is being spread to create fear and moral panic” over gender identity services. This is false. The Tavistock and Portman NHS Trust’s Gender Identity Service (GIDS) has seen an exponential rise in young women presenting to the clinic over the last twenty years. These figures are publicly available on their website. In 2004, Susan Evans raised concerns about the rapid rise in referrals of young people to the endocrine clinic. Evans says “nothing really changed” despite recommendations being made after an internal inquiry. The Tavistock has since been the subject of multiple Newsnight reports which have revealed failures in safeguarding and highlighted rushed treatment decisions. Sonia Appleby, Named Professional for Safeguarding Children and the Safeguarding Children Lead at the Tavistock, has launched a legal challenge against her employer over the issues. David Bell, a former staff governor at the Tavistock and Portman NHS Foundation Trust, “sent an internal report to its leaders in 2018, urging them to suspend all experimental hormone treatment for children who wished to change gender until there was better evidence of the outcomes.” Professor Christopher Gillberg, a global expert on autism, has warned that girls who are autistic or anorexic appear more likely to identify as transgender. Keira Bell and Sinead Watson are part of a growing number of “detransitioners” who feel that they were rushed by doctors into the decision of transitioning without proper consideration for underlying factors like mental health. Bell later brought forward a judicial review against the Tavistock, challenging its use of the “affirmative” model and Gillick competence. Last year, after reviewing the evidence base, the landmark ruling from the High Court concluded:

“The conclusion we have reached is that it is highly unlikely that a child aged 13 or under would ever be Gillick competent to give consent to being treated with PBs. In respect of children aged 14 and 15, we are also very doubtful that a child of this age could understand the long-term risks and consequences of treatment in such a way as to have sufficient understanding to give consent.”

“One of the issues raised in these proceedings is the non-existent or poor evidence base, as it is said to be, for the efficacy of such treatment for children and young persons with GD”

By this point, the rapid rise in adolescent referrals, safeguarding failures and poor evidence base for this experimental treatment have all been well documented. This is not “misinformation” or “moral panic” but well-evidenced concern that vulnerable young people are being put on an irreversible medical pathway that they might later regret. This has nothing to do with the tactics “used by campaigners against same-sex marriage who cited concerns about how the reform would pose a threat to families”. The deliberate conflation of these causes is partly why many have been afraid to question this emerging medical scandal. In light of Bell and Mrs A v The Tavistock and Portman NHS Foundation Trust, the inaccurate claim of “misinformation” within the article must be amended.

The author does not provide any references to support their claims and yet makes the bold statement that transphobia, which it has depicted as any arguments in favour of retaining biological sex as a political category, is akin to racism or homophobia. In other words, it appears that the University’s agreed position is that anyone arguing that women should have rights pertaining to sex, as enshrined in the Equality Act, is transphobic, and their desire to study, research, discuss and advocate for their rights should be considered as unacceptable as arguing for racism or homophobia. Many of the women expressing views such as the ones briefly outlined in this statement are lesbians themselves and would meet the university’s definition of trans: “choose to dress in the clothing typically worn by the other sex.”

We are concerned that students may reasonably conclude that this information has been fact checked and approved by the university given its publication on the official website. We would recommend that a disclaimer is added above the article clarifying that the views expressed belong to the author and do not reflect the official views of the university. We also suggest that university managers investigate how the article came to be published in its current form, and take steps to prevent a re-occurrence.

Research Schools

EqualiTeach and GEO Funding

On March 25th, EqualiTeach released a resource ‘Free to Be‘ which was available for 27 primary schools in London “in the early stages of their work in promoting LGBT+ equality.” This guidance was heavily criticised, in particular for misrepresenting the Equality Act (2010) and attacking the organisations Woman’s Place UKFair Play for Women and Transgender Trend.

Lizz Truss MP tweeted on the 1st May that the document “was not approved by government. It does not reflect government policy. The GEO logo should not be on it and I have asked for it to be removed.” Soon after, the UK Government Equalities Office (GEO) distanced themselves from this material and denied involvement.

In a statement, EqualiTeach said that they were “surprised” by this outcome: “EqualiTeach were provided with the GEO logo for use for communications related to the programme. The resource was sent to GEO for approval prior to publication and in conversations on the 26th March EqualiTeach was told that the GEO was happy for the logo to be on the resource.”

We were also surprised, as this document was a direct result of a project that ran from April 2019 – March 2020 which received government funding. EqualiTeach has been receiving government funding for years, which raises questions as to the lack of GEO oversight on these programmes. On our Twitter account, we posted a thread outlining GEO involvement with EqualiTeach. We are uploading here for archival purposes.

We are pleased that @trussliz & @GEOgovuk have distanced themselves from the inaccurate & irresponsible guidance published by @EqualiTeach. However, this document did not appear out of thin air. Questions need to be answered as to how government funding is being used.

EqualiTeach have been publicising this material as early as February. That a statement was only made yesterday raises serious concerns about lack of oversight on government funded programmes.

This funding was awarded last year and ran through until March 2020. This document is a direct outcome of that funding.

Confirmation of GEO funding can be found in their 2019 annual report.

This relationship looks set to continue: “The extended programme will run until March 2020, and the Government Equalities Office and Department for Education are considering jointly how to ensure this work is taken forward.”

Nature of the funding: “develop local solutions to support the progression of teachers covered by at least one of the protected characteristics as defined in the Equality Act 2010” As outlined by @MForstater, this document misrepresents EA.

Reports from 2016/17 show partnership with Teach First, as does EqualiTeach website.

Teach First received government funding to the tune of: 62% of total £52.7 million in 2017/2018; and 63% of £61million in 2016/17. Huge quantities of money spent on teaching & training materials potentially unreviewed by GEO.

In 2016, EqualiTeach partnered with Teach First to promote “Fundamental British Values”. We see the use of “inclusive” in the context of religious discrimination and the phrase “prejudice-based bullying“.

This partnership continues into 2017, where we now see the introduction of “identity-based bullying” and programmes on the topic of “equality and relationships and sex education”. With this shift, “inclusive settings” starts to take on a new meaning.

“Fundamental British Values” first appeared in relation to counter-terrorism and extremism measures in 2011 Prevent Strategy, then with regard to education in 2013 Teachers’ Standards, defined as the following:

Government guidance published in 2014 changed need for “respect” of these values to the requirement that “all schools must now have a clear strategy for embedding these values and show how their work with pupils has been effective in doing so.”

EqualiTeach’s website states that there is no clarity as to what these values actually look like despite being enforceable by Ofsted. Presumably, this uncertainty is the gap in the market that EqualiTeach are exploiting.

These groups are modelling their approach off of existing government aims and moving policy in a particular idealogical direction. Targeting schools ensures this material reaches an impressionable demographic and takes advantage of the lack of clarity within Ofsted requirements.

“Free to Be” is a direct result of long term funding from @GEOgovuk to @EqualiTeach, so it is therefore difficult to believe GEO claim of “no input”. This government-funded misrepresentation of UK law demonstrates back door policy making by unmonitored vested interest groups.

Originally posted on Twitter on 02/05/2020


Gender Recognition Reform (Scotland) Bill Consultation – XX Submission

The following is our submission for the Scottish Government’s consultation on reforming the Gender Recognition Act. Click here for a pdf version.

1. Do you have any comments on the proposal that applicants must live in their acquired gender for at least 3 months before applying for a GRC? 


The XX Gender Recognition Reform (Scotland) Bill Working Group disagree with the notion of “living as the acquired gender” as this is profoundly sexist and naturalises the idea that there are appropriate ways for the two sexes to behave. As a feminist group, we object to this biological essentialism and believe individuals should be free to express themselves in any way of their choosing and live free from discrimination. 

The Bill fails to account for the growing number of referrals for children and adolescents to the Tavistock and Portman NHS Foundation Trust (2590 in 2018-19, compared with 678 in 2014-15) and the unprecedented rise in the percentage of female referrals (1740 in 2018-19, more than double the 624 male referrals the same year). [1] The Bill also fails to account for the growing number of detransitioners expressing regret, who cite a rushed legal and medical transition as one of the failings of the current system. The Tavistock have admitted to not knowing the true extent of this problem due to lack of data and research.[2] Attempts to “streamline” this system may, in fact, have the opposite effect; amplifying the flaws of the current model and moving ahead without the necessary research and understanding. 

We share the aims of the Scottish Government to de-medicalise and de-pathologise gender nonconforming individuals, however, enshrining gender in law supports the idea that there is something somehow “different” about these individuals in that they need legal distinction. Be it for three months (the Bill) or two years (current system), we challenge the assumption that there are ways the “acquired gender” live that can be adopted by those transitioning. This term has not been defined within the Bill and would be difficult to define without reverting to sexist stereotypes.

2. Do you have any comments on the proposal that applicants must go through a period of reflection for at least 3 months before obtaining a GRC? 


We believe that the reduction of this period to three months will have serious negative consequences for women and girls. 

A three month period of “living as the acquired gender” followed by a three month “reflection” period totals only six months. Six months is an exceptionally short amount of time and many conclusions can be felt to last a lifetime during such a small window. Decisions can be made in haste and maintained for this duration that are later regretted.  As evidenced by the growing number of detransitioners, one of the failings of the current system is the speed in which one can obtain a GRC. There is misconception among the public that the current system is long, difficult and demeaning [3]; however, minutes from the Gender Recognition Panel User Group and statistics published by the Courts and Tribunals Service show that 75% applications for a Gender Recognition Certificate receive a decision within 20 weeks, and many within 6-11 weeks.[4] Over 90% of applications are successful and receive a GRC. [5

There is also an assumption that during this “reflection period” applicants will be acting in good faith. Many women’s groups, ourselves included, are concerned GRA reform will create a legal loophole which will allow predatory men to access vulnerable women with ease as well as impacting data collection relevant to male violence against women.  Under the Equality Act (2010): sex is a protected characteristic (Part 2, Chapter 1, Section 11); single-sex services are protected (Schedule 3, Part 7, Sections 26-28); as are single-characteristic associations (Schedule 16, Part 1) and communal accommodation (Schedule 23, Part 3).[6] There has been no clarity from the Scottish Government as to how ease of access to a GRC will impact on these single-sex exemptions. 

The Scottish Government have also not considered the conflict with The Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW), which protects women on the basis of sex: “The Convention defines discrimination against women as “…any distinction, exclusion or restriction made on the basis of sex which has the effect or purpose of impairing or nullifying the recognition, enjoyment or exercise by women, irrespective of their marital status, on a basis of equality of men and women, of human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field.”[7]

Section 9(1) of the Gender Recognition Act (2004) states: “Where a full gender recognition certificate is issued to a person, the person’s gender becomes for all purposes the acquired gender (so that, if the acquired gender is the male gender, the person’s sex becomes that of a man and, if it is the female gender, the person’s sex becomes that of a woman).”[8] If an individual can obtain a GRC in 3-6 months, and upon being issued with a GRC, a person’s sex “becomes that” of the opposite sex, this renders single-sex service provision unworkable and the rights women currently have on the basis of sex will be compromised. Nowhere in the bill does it state what legal right a GRC confers. This is not reasonable. 

As feminists, we are concerned about the potential impact of this legal uncertainty on marginalised women (eg. women in refuges and prisons) who lack the  necessary resources to come forward with test cases. We seek to protect the single-sex exemptions within the Equality Act and therefore do not think there is any conceivable time period which would justify compromising these protections.

3. Should the minimum age at which a person can apply for legal gender recognition be reduced from 18 to 16? 


We do not agree the age should be lowered. Lowering the minimum age pays no regard to contributing factors prevalent among adolescents, such as homophobic and sexist bullying, which may contribute to cross-sex identification. Bullying can often last far longer than 3-6 months and therefore this amount of time is insufficient in allowing for any change in circumstances that might influence such a decision. Many of our members are lesbian and bisexual and can attest to the homophobic bullying they experienced at that age, in particular, bullying due to gender nonconformity in presentation and behaviour and were consequently deeply uncomfortable with their sex. Rejection of gendered expectations (that the Bill promotes through the notion of “living as the acquired gender”) can often manifest within young people as a rejection of the sexed body. Many same-sex attracted women experience social coercion to make themselves appear “straight” and it is becoming increasingly apparent from the stories of detransitioners that transition can be a means of achieving this for gender nonconforming women. Research shows that, for the vast majority of children, transgender identification does not persist into maturity.[9][10][11][12

We do not think a 16 year old is capable of foreseeing how they may identify in the future and sign a statutory declaration on that basis. Currently, there are 592 GIDS referrals for children 16 and over.[1] This number only reflects those on a medical pathway – the figure for young people potentially impacted by this reform will likely be much higher. This problematic when considering the aforementioned research on desistance and the criminal charge introduced by the bill for false declarations. Decisions made in adolescence potentially become a punishable offence if the individual desists or detransitions. Nowhere in the Bill are detransitioners discussed. There has also been no explanation from the Scottish Government as to how this sanction will be enforced, given that there is no way of knowing the legitimacy of such a claim when the initial claim was without evidence and based on self-declaration alone.

4. Do you have any other comments on the provisions of the draft Bill?


We are concerned proposed reform also presents a conflict with the rights of lesbians and bisexual women. Same-sex attraction is a protected characteristic under the Equality Act (Part 2, Chapter 1, Section 4) and is defined with reference to sex.[13] As previously outlined, section 9(1) of the Gender Recognition Act states that upon being issued with a GRC, a person’s sex “becomes that” of the opposite sex. This renders the rights of same-sex attracted individuals unworkable. The right lesbians and bisexual women have to single-characteristic association under the Equality Act will be lost as members of the opposite sex will be rendered legally indistinguishable.

Members of XX who are also students within Scottish universities have experienced silencing and harassment on this topic and therefore feel the Bill and its potential consequences have not been sufficiently considered by many within our age group. Last year, ten events promoting transgender ideology were held at Edinburgh University, compared with just two discussing women’s sex-based rights. Out of these two events, one resulted in a speaker being assaulted by a protestor, and the other has been indefinitely postponed. Students and speakers are in a position where they fear for their safety when attending events discussing reform. 

EUSA liberation group, prior to the event, accused speakers and attendees of “transphobia” and called for the expulsion of “TERFs” (i.e. women who recognise sex differences) and have arguably contributed to this climate of fear.[14] Some of our members who are students at the University of Edinburgh have found the level of censorship and defamation of feminists to be incompatible with EUSA’s formal stance as a ‘feminist’ organisation. Our student members do not feel confident that NUS Scotland have made room for the necessary debate on GRA reform before they endorsed this Gender Recognition Reform (Scotland) Bill, as they have been unable to express criticism within NUS Scotland spaces without being defamed. Many events that seek to address the topic fall under EUSA safe space policy, which is arguably in breach of Further and Higher Education (Scotland) Act (2005) which allows for ‘freedom (within the law) to hold and express opinion, question and test established ideas and received wisdom and present controversial or unpopular points of view.’[15] Feminists, who frequently test “established ideas […] and present controversial or unpopular points of view” are being misrepresented “hateful” and “transphobic” (a view shared by EUSA liberation group) and discussion silenced in accordance with EUSA “zero tolerance” safe space policy. 

XX maintain that there is nothing hateful about discussing legislation and to argue such is a new version of misogyny that seeks to prohibit women from fully engaging in public life. As an organisation, we are united under the principle of women’s oppression being sex-based. We are concerned about the impact of the Bill on the rights of the most marginalised women who currently are protected on the basis of sex. We would recommend the Scottish Government investigate to what extent single-sex exemptions are being implemented and resolve to strengthen existing laws for women.

5. Do you have any comments on the draft Impact Assessments? 


The impact assessments are not fit for purpose.  We are concerned that the concerns of many women’s groups have not been sufficiently considered. In particular, Fair Play for Women, who have said the following:

“On 21st August 2019 the Scottish Government library was asked to perform a literature search to identify the evidence to inform the Equality Impact Assessment (EQIA) for the Scottish Government’s Gender Recognition Reform Bill. This was revealed through a Freedom of Information Request here. They were asked to find “Evidence on legitimate basis on which trans women might need to be excluded from some women-only services, locations, or provisions, or on which their presence might put non-trans women at a disadvantage.” The Scottish Government library did its job well and identified Fair Play For Women in its list of Key Results highlighting that ‘the following results may be particularly relevant’. However, none of our published resources were quoted in the final EQIA or even listed in the references. The omission of evidence from FPFW, and indeed any advocacy group for sex-based rights, means that a full and comprehensive search for evidence was not conducted by the Scottish government consultation team and this casts serious doubt over the validity of the EQIA.”[16][17

As a feminist organisation, we are worried by the omission of evidence on topics such as domestic violence, sex offenders, single-sex services, female sport and miscarriage, as was included in the Fair Play for Women references.  

Murray Blackburn Mackenzie have also expressed doubts over the draft Impact Assessments:

“The draft EQIA notes that some respondents raised concerns about the impact on gender self-declaration on data collection in the 2017 consultation. The consultation paper does not however discuss data collection in relation to the census, NHS records, criminal justice statistics, the recording of employment data and/or the impact on equal pay claims, or the need to collect sex- disaggregated data to tackle sex-based discrimination. 

Instead the draft EQIA refers to the Scottish Government Working Group on Sex and Gender in Data,59 which is chaired by the Chief Statistician and will consider what guidance should be offered to public bodies on the collection, disaggregation and use of data on sex and gender. 

The membership of the Working Group is drawn exclusively from organisations that have implemented or support gender self-identification policies and/or approaches to data collection. These include National Records of Scotland and the Office for National Statistics, both of whom have recommended that the sex question in the 2021 census is framed in terms of self-declared gender identity.” [18

We share the concerns of MBM on the potential impact of GRA reform on data collection. Accurate data surrounding representation, equal pay, healthcare and criminal justice statistics are crucial for informing feminist analysis. It is therefore vital that data relating to such remains sex-disaggregated but we do not feel this has been sufficiently considered by the Scottish Government. 

It is claimed that the existing exceptions in the Equality Act will remain in place; however, there has been no analysis on the impact of the changes to the process of obtaining a GRC, nor the expansion in the number of GRCs granted. As outlined in our response to questions 2 & 4, XX believes there is a fundamental conflict between the rights of women and the legislative changes proposed by the Bill, a conflict that has not been adequately investigated by the draft Impact Assessments.