An analogous result was reached by the European Court in the Dudgeon case.

v. Canada,d and the decision of the European Court of Human Rights in Dudgeon v. United Kingdom.e In the Toonen case, the Human Rights Committee held that the author could claim to be a victim of a violation of his right to privacy, even though he had not been prosecuted, because of the existence of a provincial law that criminalized sexual relations between consenting male adults.