female adolescent shoplifters has not been accompanied by any diminution in the concern of the children's court for the girl's non-criminal behaviour. In this community, sex differentials in children's court referrals for uncontrollability and neglect are very considerable; for example, in 1972-73, although girls
comprised only just under one-quarter of all court offenders, three and a half times as many girls than boys were referred
for non-criminal behaviours. With respect to disposition similar proportions of males and females were committed to state
institutions and children's homes in 1972-73. However, the
possibility of custodial placements in non-state institutions, by alternate court orders of wardship and committal to the care of an approved person, was much greater for girls than for boys.
In this community, the complainants for non-criminal delinquency are either parents (either directly or by admission
to the police), or police. With respect to parents, it would seem that the contention of Poliak (1950) that the home is a factor in the "masked" deviance of women does not necessarily apply to adolescent girls. The willingness of parents to contact formal control agencies for assistance in disciplining their
daughters and their use of the police in cases of runaway girls provide a major source of police contacts with adolescent girls. Parental concern for the activities of their daughters is then supported by the policewomen, who will also frequently suggest to the parents the possible use of the court, if such is not the parent's initial intention. Furthermore, the strong moral
obligation expressed by the policewomen to investigate any signs of adolescent female deviance which they themselves observe may
at times supplant any lack of concern of parents for the behaviours of their daughters.
Police discretionary action in cases of non-criminal female delinquency is not necessarily a function of lenient treatment of females because of their sex. Cautions to the
girl, for example, in instances of a runaway, under-age drinking, associating with known male offenders, truancy from school, or any other activity of the girl v/hich may be without the full knowledge and consent of parents, result from situations where a specific behaviour by itself may not be sufficient to provide evidence of uncontrollability. The only single activity which can, for the policewomen, justify immediate intervention by a court referral, is that of sex delinquency. Hence the
policewomen, as social control agents, sustain the image of the delinquent girl as a sex delinquent.
In short, the unwillingness of complainants to report female criminal behaviour, and the greater likelihood of police not to arrest females because of their sex, which are said to characterize the treatment of females relative to males in the criminal justice system, are not necessarily features of the
juvenile justice system, where non-criminal female delinquency is involved. A greater control by parents over the activities of their daughters, which is considered to be a characteristic of the socialization of females, would seem to be matched by a greater use of formal control agencies to back up the authority of the parents where girls are involved. The closer the
control agents' ideology reflects this traditional familial practice, the more strongly the sex status of the adolescent girl is enforced, not only in the more explicit areas of sexual
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behaviour, but in the general dependency of the girl on her parents, which is characteristic of the child status.
Finally, in the juvenile court's handling of female non criminal delinquency the protectiveness exhibited by the
criminal justice system toward adult women, and resulting in a low probability of imprisonment, appears to operate on a
different level in response to the "waywardness" of adolescent girls. The findings of the present study demonstrate that the outcome of such response results in the possibility of
institutionalization of the delinquent girl even on a first court appearance. If the justification for dealing more
leniently with adult female offenders is to protect them from the harshness of the penal correction system, then such an ideology is clearly not operative to the same extent with adolescent girls.
The essential difference is that the protectiveness towards girls is set within the context of juvenile court philosophy. The ideology which supports the inclusion of non criminal behaviours within the jurisdiction of the juvenile court does not reflect a concern for the protection of
individuals from a penal system. The juvenile court system in itself is perceived as mitigating the harshness of the adult criminal justice system; and furthermore, intervention in non criminal delinquency is justified in terms of protecting the juvenile from a social or fmailial environment which is not
conducive to the inculcation of the "right" values and attitudes. The social welfare ideology of delinquency control, where
intervention is seen as being in the interests of the juvenile rather than the community, can be used as a rationalization and
justification for the handling of non-criminal delinquency much more easily than in cases of criminal delinquency. In the
disposition of criminal delinquency, a concern for the level of seriousness of the offense and the prior record of the offender in terms of the protection of persons and property would appear to intrude more frequently.
Thus institutionalization on the grounds of the
protection of the girl in her own interests can be imposed as a delinquency control measure for girls even on a first court appearance, still within a context of the traditional ideology with regard to females. As this study suggests, such a measure
is more likely to be imposed when the institution is itself evaluated as a viable form of treatment. It would appear also that it is only when the court demonstrates a concern for the application of legal principles in the adjudication and the disposition process in terms of attempting to set some kinds of criteria defining uncontrollability or exposure to moral danger, other than those presented by the users of the court, that the
juvenile court may operate to protect the girl from the penal system.
The findings of this study suggest that a major concern of the court in disposition decisions is for the custody of the girl. For the protection of females, when they are adolescent,
includes a concern that a responsible person is able to provide the necessary supervision of the girl. Like the child, the adolescent girl must assume a dependency status,if not within the family, then in a situation of extra-familial custody. Socialization into dependency is in itself socialization into a traditional female trait, such dependency being intimately related to the family situation both for the female as a child
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