 While much of the activities surrounding prostitution were initially criminalised "de jure", "de facto" the situation was one of toleration and containment of 'a necessary evil'.Laws against prostitution existed from the founding of the State in 1851.The "Vagrant Act 1852" included prostitution as riotous and indecent behaviour carrying a penalty of imprisonment for up to 12 months with the possibility of hard labour (Part II, s 3).