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Film and Publications Act:
Child pornography means any image, however created, or any description or presentation of a person, real or simulated, who is, or who is depicted or described or presented as being, under the age of 18 years, of an explicit or sexual nature, whether such image or description or presentation is intended to stimulate erotic or aesthetic feelings or not, including any such image or description of such person
No, if she's 19 and nude by default she is been depicted as a person she is at the age she's at.Possess a nude photo of her and you can be arrested in SA.
Edit:
The Films and Publications Act, 1996 defines “child pornography” as any image, real or simulated, however created, depicting a person who is or who is shown as being under the age of 18 years, engaged in sexual conduct or a display of genitals which amounts to sexual exploitation, or participating in, or assisting another person to engage in sexual conduct which amounts to sexual exploitation or degradation of children.
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An overview on the law on child pornography in South Africa – PPM Attorneys
What are the dangers of posting nude pictures of a child online?www.ppmattorneys.co.za