Ross's article (1996) comes at a time when there is widespread concern in England about the adverse consequences of teenage sexual activity. Differences in the provision of health care and law between England and the United States mean that although the fundamental issues are broadly similar, the English situation is different in several important respects. In English law, a child under the age of 16 may consent to medical treatment provided he or she is capable of understanding what is proposed and of expressing his or her own wishes (Gillick v. WN& WAHA, 1985). Over the age of 16, a young person is assumed to be competent. Because the National Health Services (NHS) provides free access to medical care for everyone, adolescents frequently attend their family doctor on their own. Surveys show that at age 15, just over 50% of boys and just under 60% of girls attend primary health care services without a parent (Macfariane and McPherson, 1995). Thus, autonomous decision-making in the field of health care is not unusual for teenagers in England, unlike in the United States where, as Ross points out, an adolescent cannot consent to a throat culture or other treatment, but can request contraceptive medication without parental consent. However, the situation in England is not without its paradoxes. Under English law, sexual intercourse with a girl under 16 is unlawful. Sexual activity in this age group is not uncommon, and survey estimates of first intercourse below the age of consent vary from 25-65% (Wei lings et al., 1994; Maddock and Brinkworth, 1996). In practice, prosecutions for sex with a minor are rarely brought. On the issue of a child's capacity to consent, the Gillick ruling (referred to above) was modified in the case of Re /? (1991), where it was held that a parent could overrule a competent minor who was refusing treatment, but not one who accepted or requested treatment. As a result of these contradictions, a recent report from the Institute for Public Policy Research (Alderson and Montgomery, 1996) has called for an urgent clarification of the law regarding children's consent to medical treatment. The question of whether a doctor can lawfully provide contraceptive treatment to a girl under the age of 16, without her parents' knowledge or consent, was aired in full in the English courts in the 1980s. Mrs. Victoria Gillick, a practicing Catholic, started proceedings against her Regional Health Authority because they would not give an undertaking to inform her if any of her daughters requested contraception before they reached the age of 16. A lengthy hearing followed, through the High and Appeal Courts, ending in the House of Lords, who found against her by a majority of three to two. In the course of the hearings, however, a total of five judges found in Mrs. Gillick's favor and four against her, which some commentators have taken to indicate a general level of disquiet about the issues involved. Kennedy (1988) gives a full analysis of the case and charts its course to the final decision, which established a minor's right to authorize treatment without parental consent. With regard to Ross's paper, the two most important issues in the final judgment are those of parental and the competence of minors. Parental were deemed to arise from parental duties, and it was argued that these are dwindling rights as the child gets older. Parental duties exist for the benefit of the child, and it was envisaged that there might be occasions when a doctor was a better judge of advice and treatment which will conduce to a girl's welfare than her parents (Lord Fraser in Gillick v. WNaWAHA, 1985). The capacity to consent in law, it was decided, was not a matter of age, but of ability. Lord Scarman said,