Campaign looks to Europe for help: Martin Whitfield on how other countries outlawed bias against homosexuals

CAMPAIGNERS for lowering the age of consent for homosexuals from 21 to 16 believe they have the strength of Europe on their side.

Britain's laws are the most restrictive in western Europe; it has the highest age of consent for homosexuals among 27 countries surveyed by Stonewall, the homosexual pressure group, and is also one of the few countries which still discriminates between homosexuals and heterosexuals.

Angela Mason, executive director of Stonewall, said the attitudes of other countries should not be discounted: 'Just because everybody else does it need not make it right. But the experience of other countries is quite persuasive and it would suggest that a common age doesn't cause any problems. It doesn't make young men vulnerable, but recognises gay men as full citizens like everybody else.'

Ireland, the most recent country to change its laws, has had a common age of consent of 17, the earlier heterosexual limit, since legislation was reformed in June last year. Its government opted to follow a recommendation from a law reform commission to refuse to discriminate between heterosexual and homosexual relations.

David Norris, the homosexual Irish senator, whose successful appeal to the European Court of Human Rights eventually led to the law being changed, said the struggle had been worthwhile. 'The only reason for having a different age of consent is to discriminate by leaving one person inferior to another. Lowering the age removes the criminal stigma and provides the basis for civil rights for gay people,' he said.

Kieran Rose, chair of the Gay and Lesbian Equality Network, said Ireland had been transformed from one of the more repressive regimes for homosexuals to one in which the Ministry of Defence had proposed to outlaw discrimination in the defence forces and employment laws were being brought forward to prevent dismissal on the grounds of sexual orientation.

'The common law offence of buggery has been repealed. The law is gender neutral,' he said.

Legislators in Germany are committed to reforming the law which currently discriminates against men, with the age of consent of 18 for homosexuals compared to 14 for heterosexuals. The most likely option is a common age of 16.

Many states of the Commonwealth have also changed their age of consent. In New Zealand, a country with similar laws to Britain, the age of consent was equalised at 16, in 1986. Dire predictions of the consequences were made at the time, but have not materialised.

Doug Kidd, Minister of Fisheries in New Zealand, made his position clear on the Homosexual Law Reform Act when he spoke on the Human Rights Bill last year: 'Many of us - and I was one of them - throught the sky was going to fall in, if that legislation was passed.

'I have to report that the sky is still up there and that, one way or another, society has muddled on. Armageddon has not come.'