The phrase 'intent to defraud' in s 409(1) of the Criminal Code (WA) does not extend to inducing a person to accept gratuitous services (including medical treatment) through misrepresentation of qualifications where no economic interest, public duty, or private reputation/personal status is affected. Prosecutors seeking to charge conduct involving interference with the person through deception must rely on offences against the person (such as assault) rather than the fraud provisions. It remains an open question whether 'intent to defraud' extends to non-economic interests such as private reputation or personal status.
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