Written evidence submitted by Dominica Maxted [GRA1389]

Submission – Reform of the Gender Recognition Act

I am a private individual and have been involved in the self id debate for several years. I think I’m a fairly typical gender critical feminist, but I don’t claim to speak for anyone else. I am mainly active on Twitter where I have around 3000 followers. I have attended meetings run by Women’s Place UK, Fair Play for Women and Standing for Women. I regularly write to my MP and organisations that are not upholding women’s sex based rights. I am extremely concerned about the loss of women’s rights to single sex spaces such as shelters, changing rooms, hospital wards and prisons and the right to women only sports and women only shortlists.

I don’t understand why women are expected to keep defending our rights in law. It seems that we are being worn out, bullied until we agree.
What this is doing to the mental health of women who understand the situation - that the GRA means giving up our rights in law - is incalculable.

Remember this – There is nothing more likely to generate distrust in government, to increase tensions in society, and promote distrust in the legal system than telling citizens to repeat a lie. We are now being told that human beings can change sex and that someone who was once a man is now a woman. This is a lie that is massively damaging to women, is anti science and anti freedom of speech.

  1. Will the Government’s proposed changes meet its aim of making the process “kinder and more straight forward”?

    What is missing here is any consideration of what is kind to women. Is it kind to tell us that our sex does not exist, that a feeling in a man’s head is more important than our reality? To remove our ability to monitor and plan for the needs of our sex by removing the language we need to talk about our issues? Why should it be more straight forward for males to appropriate the rights of women?
  2. Should a fee for obtaining a Gender Recognition Certificate be removed or retained? Are there other financial burdens on applicants that could be removed or retained?

    It should be retained. Anything that makes people really consider before taking this step that may include medicalising those people for life, undergoing unnecessary and risky medical procedures, all without due cause for consideration, should be encouraged.
  3. Should the requirement for a diagnosis of gender dysphoria be removed?

    Absolutely NOT. This will give access to women’s safe spaces to anyone who wants it. To be clear, I do not think any male should have access to these spaces. By removing this barrier you are opening the door to any autogynephile who wants access to vulnerable women and allowing women to be used as a prop in a fetish.
  4. Should there be changes to the requirement for individuals to have lived in their acquired gender for at least two years?

    What does this even mean? Wearing a skirt? Using a typically female name? Neither of which I do, and I am an actual woman. It’s utter nonsense.

    Unless you can define gender, it should have absolutely no basis in law.
    Given that you will not provide an answer to this, I would say no. Anything that provides a pause before males can access our spaces may keep some of the predators out.
  5. What is your view of the statutory declaration and should any changes have been made to it?

    It is absolutely inadequate. Gender is meaningless and you provide no definition. People’s view of their gender should have nothing to do with their ability to access sex based spaces or roles. Declaring how you feel and how you think you live is something that should stay in magazine quizzes. Anyway, this form does not appear to cater for the 100s of new ‘genders’ that appear every day.

    Let people live how they want, but decouple gender from sex, which is binary and immutable. If necessary, provide a separate category on official documentation.

    Also, how is the declaration provable? How can anyone be penalised for lying? If they cannot be, what is the point of the declaration in law?

    Where does this leave detransitioners? People should be able to change their minds and prosecuting detransitioners would be cruel, but this means that no sanction will exist for those who lie to access women’s spaces. 

    I hope our govt is not so naïve as to think males will not use this loophole. They have used every loophole available to access women and children. What makes you think that they won’t use this? Or do women and children not matter?
  6. Does the spousal consent provision in the Act need reforming? If so, how? If it needs reforming or removal, is anything else needed to protect any rights of the spouse or civil partner?

    Spouses and civil partners should absolutely have the right to immediately dissolve this legal contract because the terms of the contract have fundamentally changed.
  7. Should the age limit at which people can apply for a Gender Recognition Certificate (GRC) be lowered?

    Absolutely not. It is clear that something very dangerous is happening with children, especially female children, who are trying to identify out of their sex. This is what you should be looking into. Why are so many female children doing this? I suggest that it is a response to the utter contempt for women in society, which this consultation, and the repeated chipping away at our protections in law, is part of.

    All the studies have shown that children who with self identification continue down the path to life long medicalisation, ending with weakened bones, compromised cognitive development, impaired sexual function, infertility, the removal of healthy organs, and reduced life expectancy. The NHS has obviously reconsidered the harmful impact of puberty blockers as it has recently changed its guidance.

    Keep this ideology away from children. The only people you are helping here are the lawyers who will eventually be suing everyone involved.
  8. What impact will these proposed changes have on those people applying for a Gender Recognition Certificate, and on trans people more generally?

    Once again, you completely ignore the impact on women.
    There are many different types of trans people. There are those who have genuine dysphoria who will surely welcome increased medical care and gatekeeping. There are also autogynophiles who will be very disappointed if they are not allowed access to vulnerable women. Children may not appreciate having to wait for anything, they rarely do, but as the adults it is our responsibility to safeguard them from making the wrong decision.

  9. What else should the Government have included in its proposals, if anything?

    Women. You seem to have forgotten that these changes affect us.
    It should have included the fact that changing gender does not change anyone’s sex. I am happy for anyone to present and refer to themselves however they like but this should never be at the expense of women’s sex based rights.

    No one should be able to change the sex on their official documents. Women should have the right to same sex shelters, prisons, health care providers, sports and scholarships. The govt needs to ring fence our rights. We need to be able to bar males from certain women’s spaces and from certain jobs, such as intimate health care. How can we do this if males are enabled to change their documentation?
  10. Does the Scottish Government’s proposed Bill offer a more suitable alternative to reforming the Gender Recognition Act 2004? 

    The Scottish Government has been completely captured by the trans lobby. Please do not look to them for anything.


  1. Wider issues concerning transgender equality and current legislation:
  2. Why is the number of people applying for GRCs so low compared to the number of people identifying as transgender?

    Possibly because many of them are keeping their options open. They know that they don’t have gender dysphoria so are hedging their bets and getting the best of both worlds. For many, this is a trend. It will go the way of other trends. Some young people may be aware, on some level, that this is a phase and they will grow out of it.
  3. Are there challenges in the way the Gender Recognition Act 2004 and the Equality Act 2010 interact? For example, in terms of the different language and terminology used across both pieces of legislation.

    Yes. Both conflate sex and gender which are very different things, however holding a GRA implies that someone has changed sex, when this is patently nonsense.

    The Equality Act Exemptions state that women’s sex based rights can be upheld, but the GRA and the accompanying ability to change legal documents makes this impossible to enforce.
  4. Are the provisions in the Equality Act for the provision of single-sex and separate-sex spaces and facilities in some circumstances clear and useable for service providers and service users? If not, is reform or further guidance needed?

    They are very unclear. Much of the extremely toxic debate around this subject is due to the fact that no one is clear on the law. The govt urgently needs to provide clear guidance, that does not conflate sex and gender, that defines ‘gender’ and specifies who exactly is allowed where.

    Why are male offenders being put in women’s prisons? Even if they have a GRC, they have changed their gender, not their sex. Even the Geneva Convention does not allow this for prisoners of war. Why are women in this country given less protection?

    Can women ask for a biologically female health care practitioner for intimate care, for example? This is a reasonable request, but how can this work in real life if transwomen can provide a passport which states that they are women? Surely the govt cannot refuse women the permission to choose the sex of someone who is giving her a smear? Should a woman in hospital have to submit to intimate care provided by a male? Where does this leave victims of male abuse? Religious women?

    This gives priority of one protected characteristic over another. This will further create tensions between the characteristics and women will opt out of health care. The result will be more female deaths.
  5. Does the Equality Act adequately protect trans people? If not, what reforms, if any, are needed

    What rights, explicitly, are trans lobbyists requesting? It appears that this is a single issue campaign to remove the rights of women. To allow transwomen  to access the spaces and sports that were hard won by women, thus destroying these rights.

    What more do they need? They have everyone rooting for them. Money from big pharma, cosmetic surgeons, banks even coffee chains. The police visit feminists for being annoying on Twitter, but threats to rape and kill women are ignored. Trans people are the most powerful ‘oppressed group’ in history.

    If you want to protect them, protect women before there is a huge backlash which will hurt not only trans people but LGB. I follow many transpeople on Twitter who are extremely alarmed at the damage being done to their reputation by aggressive lobbyists.
  6. What issues do trans people have in accessing support services, including health and social care services, domestic violence and sexual violence services?

    While trans people obviously need access to these services, it is necessary that this does not come at the expense of women and their need for same sex spaces, in particular when they are recovering from male abuse.

    I have recently been talking to a woman who runs such a centre. She is powerless to refuse entry to the many males who present, part time, as women, and use the lack of legal guidance to gain access to vulnerable women.

    Why are you not asking about the impact on women?
  7. Are legal reforms needed to better support the rights of gender-fluid and non-binary people? If so, how?

    No. These are imprecise terms. Lack of clarity makes for bad laws.

    Everyone is gender fluid and non binary. To suggest that most women are naturally gender conforming is sexist and regressive. What is important is people’s sex.

    The govt is going to look extremely foolish by indulging this narcissism and woolly thinking.

November 2020