Doesn't the following, from Ch.12, get as near as dammit to intimate touching? (Children - look down now.)

...they were whispering and talking together as fast as could be, and he seemed to be begging something of her, and presently he took up her scissars and cut off a long lock of her hair, for it was all tumbled down her back; and he kissed it, and folded it up in a piece of white paper, and put it into his pocket-book.

OK, so he wasn't touching her skin, but touching someone's hair in this fashion is even now, let alone then, a no-no unless the hairs' owner is agreeable.

And, as he was cutting the lock off, it would have been all too easy for Willoughby's hand to "accidentally" brush against her back.