Constance May Bienvenu: Animal Welfare Activist to Vexatious Litigant

32 Pages Posted: 3 Mar 2009 Last revised: 15 Apr 2009

See all articles by Simon B. Smith

Simon B. Smith

Monash University - Faculty of Law

Date Written: February 19, 2009


Constance May Bienvenu (1912-1995) was a passionate animal welfare activist. She was also the fifth person declared as a vexatious litigant by the Victorian Supreme Court (1969) and the first woman declared by the High Court (1971). In the 1960s Bienvenu led a reform group that challenged for control of a conservative RSPCA (Victoria). Though unsuccessful, there were significant consequences from the legal challenges. This article explores the passion and extraordinary determination of Bienvenu and her supporters. It traces the responses of a conservative RSPCA and its legal advisers struggling to maintain the status quo and notes the unintentional consequences of involving the legal system in community disputes. Finally, by tracing Bienvenu's determination to secure substantive reform, this article demonstrates the challenge self represented activism presents to a legal system more comfortable with arcane procedures and legal form.

Keywords: vexatious litigants, Constance May Bienvenu, animal activist, legal history

JEL Classification: K0, K00, K10, K19, K30, K39, K41

Suggested Citation

Smith, Simon B., Constance May Bienvenu: Animal Welfare Activist to Vexatious Litigant (February 19, 2009). Legal History, Vol. 11, p. 31, 2007; Monash University Faculty of Law Legal Studies Research Paper No. 2007/04. Available at SSRN:

Simon B. Smith (Contact Author)

Monash University - Faculty of Law ( email )

Wellington Road
Clayton, Victoria 3800

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