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A man from regional Victoria has become the state’s first person to plead guilty to multiple counts of rape under new laws that expand the definition of the offence to include those who refuse to pay sex workers for their services.
Similar legislation introduced in NSW resulted in the conviction last month of a man from Sydney’s eastern suburbs, who had falsely claimed he had transferred $1600 to a sex worker from Melbourne.
Both men were charged under affirmative consent laws, which mean a false or misleading representation about payment to a sex worker can be classified as rape or sexual assault.
Victoria passed the revised consent laws in July 2023, while NSW introduced similar legislation regarding deceptive procurement a year earlier. In both states, consent is conditional on payment when a client agrees to a commercial arrangement with a sex worker.
Last month, Oliver Graoroski pleaded guilty to 20 charges of rape in the Shepparton Magistrates’ Court.
The 46-year-old from Kialla, south of Shepparton, also pleaded guilty to two counts of making a false or misleading representation to engage a person for sex.
Graoroski engaged five sex workers between January and May 2025 and participated in a range of sexual acts, which he refused to pay for, according to charge sheets released to this masthead last month.
Appearing via video link , Graoroski admitted to “making a false or misleading statement to engage in a sexual act” with another sex worker in March 2022, which occurred before the affirmative consent laws were introduced in Victoria.
Graoroski is due to appear for a plea hearing before the County Court of Victoria in October.
In May, Samuel Roy Christie from Rose Bay was found guilty by a jury of sexually assaulting a sex worker following a trial at the Sydney Downing Centre District Court.
The 34-year-old, who claims online to be the general manager of a media and advertising agency, is the first person in NSW to be found guilty of the charge after electing to proceed to trial.
Christie admitted to engaging Melbourne-based sex worker Isabella St James after an evening consuming cocaine, but falsely claimed he had paid her in cash.
St James gave permission to this masthead to be identified by her working name and agreed to be photographed. She said Christie needed to be held to account, but also wanted to take a stand on behalf of other sex workers.
“I actually have the privilege to do something here to make sure it doesn’t happen to someone else,” she said.
“I’ve got a super supportive family, super supportive friends, and I have a good sense of self, whereas plenty of people don’t have that privilege.
“It is quite a long process to go through, too. It’s been two years of my life, kind of hanging in limbo.”
During the trial, screenshots of false bank transfers to St James were tendered as evidence to prove Christie had planned to intentionally defraud her and entice her to engage in sexual acts.
The jury heard that at 2.25am on November 10, 2024, Christie messaged St James on WhatsApp, asking if she was available.
Hi Isabella im Sam. Nice to mee (sic) you Ive had a bit of a night,” he wrote. “Are you free to come to Rose Bay by chance?”
When St James agreed to meet up, she asked for a $200 booking deposit – a standard practice for most sex workers. Within 10 minutes, Christie had sent her a screenshot purporting to be a “successful transfer” of $1600 into her account. Two minutes later, he sent another screenshot of his bank account details.
The following morning, when St James had still not received payment, she noticed that Christie had deleted several WhatsApp messages, including screenshots he’d sent “proving” payment, a selfie he’d sent her to book her services, and his address.
However, St James had taken screenshots of their entire exchange and warned Christie she’d be reporting him to police, as “nonpayment of services is rape”. He never responded and blocked her number.
When police obtained Christie’s bank statements, there was no record of any payment to St James. And neither of his two bank accounts had sufficient funds to make payment – one was empty, while the other was overdrawn by $967.
It was revealed during the trial that Christie received a Job Seeker allowance but had also “regularly requested his parents to transfer money into his accounts”.
In her evidence, St James said there was no way she would have agreed to any sexual service if she knew she hadn’t been paid.
“Absolutely not,” she said during the trial. “I simply wouldn’t be there providing a service if there was not any monetary gain. It’s my profession and job.”
After deliberating for just over an hour, a jury agreed St James had not been paid and did not provide consent.
“The transfer receipt in fact related to a future-dated single funds transfer … the transfer was never executed by the offender,” Judge Nicole Noman said at a sentencing hearing on July 31.
“Prior to, and throughout the sexual activity, the victim believed she had been paid by the offender for the provision of sexual services, because of his provision of screenshots of the bank transfer and bank account transactions earlier,” Noman said.
Christie was sentenced on July 31 to four years’ imprisonment, with a non-parole period of two years and four months.
St James said she felt vindicated by the verdict and the custodial sentence. She said Christie never showed any contrition, while his legal team had repeatedly attempted to discredit her and her profession during cross-examination.
“This conviction confirms what I have always known: what happened to me was wrong, it was criminal, and it mattered. You thought my occupation made me powerless. You thought I would stay silent, that I would be too ashamed to come forward, and that no one would believe me. You were wrong,” she said.
“I still haven’t gotten paid, but it’s good that I know that this can’t happen to anyone else. It’s good that the law is on my side here.”
St James said every person had the right to bodily autonomy, which is now supported by the law.
“I hope this case stands as a reminder that consent is never conditional, negotiable, or diminished by a person’s occupation,” she said.
Until the recent introduction of affirmative consent laws, sex workers had relied on an industry-wide database known as Ugly Mugs, which was founded by the Prostitutes Collective of Victoria in St Kilda in 1986 and has been replicated around the world.
The site, which can only be accessed by sex workers, allows them to share information about clients who were abusive, violent, or had failed to pay for services.
Southside Justice senior lawyer Emily Smith commended sex workers who reported non-payment and other abuse to police.
“We acknowledge the courage of sex workers who have come forward to seek justice in the same legal system that criminalised them for their job only a few years ago.
“Sex workers, like all workers, have the right to safe workplaces and are important stakeholders in holding sexual offending accountable in our community,” Smith said.
She said clients who make false or misleading representations to induce consent from a sex worker resulted in a “serious violation of bodily autonomy”.
“This is not merely dishonest – it is a serious sexual offence, and Victorian affirmative consent reforms introduced in July 2023 appropriately reflect that.”
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