77313618.2-67.6Virginia Decodedhttps://vacode.org2016Crimes And Offenses GenerallyCrimes Against The PersonCriminal Sexual AssaultProof of physical resistance not required1981, c. 397.Farish v. Com.Record No. 0112-84346 S.E.2d 7361986-08-05https://www.courtlistener.com/opinion/1318544/farish-v-com/ . . . that it is contrary to the law. We agree. . . . <abbr title="Court of Appeals">COA</abbr>http://law.lis.virginia.gov/vacode/18.2-67.6//18.2-67.6/18.2/4/7/18.2-67.6The Commonwealth need not demonstrate that the complaining witness cried out or physically resisted the accused in order to convict the accused of an offense under this article, but the absence of such resistance may be considered when relevant to show that the act alleged was not against the will of the complaining witness.section1