The first Australian state to deal with marital rape was South Australia, which in 1976 partially removed the exemption. Section 73 of the "Criminal Law Consolidation Act Amendment Act 1976" (SA) read: "No person shall, by reason only of the fact that he is married to some other person, be presumed to have consented to sexual intercourse with that other person". Nevertheless, the laws did not go as far as equating marital with non-marital rape; the law required violence or other aggravating circumstances, in order for an act of marital intercourse to be rape. The first Australian jurisdiction to completely remove the marital exemption was New South Wales in 1981. Western Australia, Victoria, and ACT did the same in 1985; and Tasmania in 1987. In 1991, in "R v L", the High Court of Australia ruled that "if it was ever the common law that by marriage a wife gave irrevocable consent to sexual intercourse by her husband, it is no longer the common law." The case led to South Australia changing its law in 1992.