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However, it has been held that the word "person" in s5 of the NSW Summary Offences Act is not limited to "penis" or "vulva". For example, in R v Eyles the offender was seen masturbating in his front garden and charged with obscene exposure under the NSW Act. The Indian Penal Code IPC is often used to charge sex workers with vague crimes such as "public indecency" or being a "public nuisance" without explicitly defining what these consist of.