SOURCE: Parkes, Adam. “Lesbianism, History, and Censorship: The Well of Loneliness and the Suppressed Randiness of Virginia Woolf's Orlando.” Twentieth Century Literature 40, no. 4 (winter 1994): 434-60.

In the following essay, Parkes compares the treatment of lesbian themes in The Well of Loneliness by Radclyffe Hall, which was declared obscene by the British courts, and Orlando by Virginia Woolf, which was not.

At Bow Street Magistrates Court on 16 November 1928, Sir Chartres Biron ordered the destruction of Radclyffe Hall's The Well of Loneliness, a polemical novel pleading for social tolerance for lesbianism. It is tempting to think that Hall got into trouble simply for raising the issue of lesbianism, since female “sexual inversion” (as it was then known) was not legally recognized in early twentieth-century Britain. A proposal to extend to women the 1885 Labouchère Amendment, which outlawed “acts of gross indecency” between men, ran aground in the House of Commons...