In R v Bowden, a 1999 appeal, the English Court of Appeal dismissed a defence effort to depart from the literal rule, the taking of the natural meaning of statutory language. It concerned the making (copying with knowledge of the content) of an indecent photograph of a child. It confirmed it was irrelevant as to whether the offence was committed that these actions were part of a much larger production and distribution effort. That would likely be a relevant consideration at the time of sentencing if the jury found the facts established guilt.
Bowden had been convicted at the Crown Court (by jury) in Cambridge on 12 counts of making indecent photography of a child contrary to section 1(1)(a) of the Protection of Children Act 1978. Before amended by the Criminal Justice and Public Order Act 1994, section 1(a) of the 1978 Act read:
1.- (1) It is an offence for a person- <br />
:(a) to take, or permit to be taken, any indecent photograph of a child