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Other jurisdictions prohibit any female chest anatomy by banning anatomical structures that lie below the top of the areola or nipple. It is legal to sunbathe topless in France, although local regulations may ban the practice with directives about clothing.

In 2009, the appellate court declared both women to be innocent, [91] because the city staff were unable to prove that anyone at the beach was indignant or scandalized by their toplessness, and no complaint was ever reported.It first appeared in print in Look magazine, introducing the concept of a topless swimsuit into commercial fashion. In 2022, a woman in Berlin was told to cover up her chest at a public swimming pool, and was forced to leave when she refused to do so. In contemporary society, the extent to which a woman may expose her breasts depends on social and cultural context.

However, the local council said there were no bylaws dealing with the issue, and that nudity was not an offence. For example, in the annual Reed Dance festival mature girls between the ages of 16 and 20 dance topless before the Zulu king.

Breast-baring female fashions have been traced to 15th-century courtesan Agnès Sorel, mistress to Charles VII of France, whose gowns in the French court sometimes exposed one or both of her breasts. In many European societies between the Renaissance and the 19th century, exposed breasts were acceptable while a woman's bared legs, ankles or shoulders were considered risqué. And if nudity was so naturale, why wasn't there one penis appearing in the media for every pair of breasts?