Whether English Abortion Law Achieves a Balance between Women's Autonomy and Foetal Life Respect - Research Paper Example

Assess whether English abortion law achieves an appropriate balance between womens reproductive autonomy and respect for foetal life By Course University Date Introduction Since women bear children and are ultimately responsible for their care, a woman is entitled to reproductive autonomy. Reproductive autonomy therefore suggest that women are at liberty to determine how many children they wish to have and how far apart they want to have children.1 The issue of abortion, a right recognized as a woman’s right to reproductive autonomy is offset by acknowledgement that the life of the foetus, although dependent of the pregnant woman should be given due consideration.2 Abortion laws, typically endeavour to create and facilitate ‘legal abortions’ that strike a fair balance between reproductive autonomy and respect for foetal life or some sort of ‘reproductive justice’.3 Abortion laws however tend to reflect a restraint on a woman’s reproductive autonomy measured against laws that protect a number of ‘interests’ including foetal rights to life, and in many cases the ‘obligations arising from marriage and family life’.4 Under English law, the Abortion Act 1967 as amended by the Human Fertilisation and Embryology Act 1990, abortion is legalised but restricted in a way that arguably disregards a woman’s reproductive autonomy. This is because an abortion is legal only when at least two doctors determine that termination of a pregnancy is required for the health or life of the pregnant mother and/or the child.5 However, doctors can broadly interpret medical reasons for an abortion so that an unwanted pregnancy can be determined to be detrimental to the health of the pregnant woman.6 Doctors mindful of ‘wrongful birth’ claims have facilitated abortions that are not purely for medical reasons, but based on the mental wellbeing of a woman who does not want the pregnancy to continue.7 While the 1967 Abortion Act indirectly facilitates and supports a woman’s reproductive autonomy, it falls short of respecting foetal life. Pursuant to Section 1of the 1967 Act, an abortion is legal when the foetus is no older than 24 weeks. Although Section 1 of the 1967 Act protects the foetus’ life after 24 weeks, the right of the foetus to live prior to this time is forfeited to the pregnant woman whose health prevails.8 By permitting doctors’ a wide discretion and protecting the life of the foetus after 24 weeks gestation, it can be argued that in early pregnancy, the life of the foetus is not respected. Once the foetus is in the 24th week, the reproductive autonomy of the pregnant woman is not respected. The question for consideration is whether this shifting of rights before and after 24 weeks gestation strikes a fair balance between a woman’s reproductive autonomy and respect for the life of the foetus. This paper analyses this aspect of the abortion laws in England and argues that since women have a right to terminate pregnancy within 24 weeks of pregnancy, the abortion laws favour women’s reproductive autonomy. At this point, the life of the foetus is immaterial and only after a pregnant woman fails to act within this time frame is the foetus protected. Therefore, it is ultimately the pregnant woman’s decision to make, knowing that one the pregnancy progresses beyond 24 weeks, abortions are unlawful. Women’s Reproductive Autonomy under English Law Abortions are legal if they meet one of four conditions provided two ‘registered medication practitioners’ acting in ‘good faith’ confirm one or more of the conditions exist.9 The first condition, requires that the pregnancy is no more than 24 weeks and that the pregnancy would ‘involve a risk’ that exceeds the risk associated with the termination of the pregnancy.10 The second condition is that the abortion is ‘necessary to prevent grave permanent injury to the physical or mental health of the pregnant’ woman.11 Thirdly, the abortion is necessary for saving the life of the pregnant woman.12 Finally, the abortion is necessary if after birth, the child would have ‘such physical or mental abnormalities as to be seriously handicapped’.13 Moreover, when determining whether or not the pregnancy presents a risk to the health or life of the pregnant woman, regard ‘may be taken of the pregnant woman’s actual or reasonably foreseeable environment’.14 It is also important to note that unless the abortion is necessary to save the life of the pregnant woman, or to ‘prevent permanent’ mental or physical injury to the pregnant woman, a doctor’s involvement in the procedure must be voluntary.15 Given that the 1967 Act for the most part, confers upon doctors, the discretionary authority over the abortion decision, it has been argued that the Act’s purpose is to transfer the issue of ‘women’s fertility’ to ‘medical control’.16 For example, Jackson argues that a woman cannot simply decide to terminate an ‘unwanted pregnancy’, even where she might satisfy the abortion requirements under Section 1 of the 1967 Act.17 Moreover, the 1967 Act does not require that the conditions permitting an abortion are met, but merely relies on the opinions of two medical practitioners. Doctors are therefore only required to form an opinion that a specific case fits within Section 1 of the 1967 Act and not that the case is ‘in fact’ a Section 1 case.18 Therefore, if a pregnant woman’s case does not fall within Section 1 of the 1967 Act, doctors’ opinions that her condition does fit Section 1, renders the abortion legal provided the doctors are acting in good faith.19 Stauch, Wheat and Tingle argue however, that while it can be argued that a woman’s reproductive decisions reside with the medical profession, it is only a ‘symbolic’ gesture.20 After all, the law facilitates abortion in much the same way as any other medical treatment in which medical opinion is required.21 Moreover, Section 1(2) of the Abortion Act 1967 requires that doctors take into consideration the pregnant woman’s environment and therefore suggests that ‘her social circumstances are clearly relevant’ when assessing ‘her medical need’ (Jackson, 2001:80).22 Thus as Jackson puts it: Given an elastic definition of health, and the relevance of a woman’s environment, it could be argued that the ‘social’ ground operated in practice to render every pregnancy lawfully terminable within the first 24 weeks, and as a result is largely redundant as a qualifying condition.23 The social ground is therefore said to confer reproductive autonomy on the pregnant woman since, medical practitioners are not at liberty to simply decide that a pregnancy will be aborted because the pregnant woman’s physical or mental health will be worsened by the pregnancy.24 Nor can doctors approve abortion based on an opinion that the baby will be born with a serious handicap.25 Rather, it is generally accepted that doctors will usually make a decision after a pregnant woman requests the abortion.26 In practice, ‘the wishes of the pregnant woman will usually be the principal factor in persuading doctors to certify an abortion’ under the Abortion Act 1967.27 The involvement of doctors can therefore be said to be necessary since abortion is a medical procedure. Prior to the legalization of abortions, pregnant women engaged in dangerous procedures that were either poorly regulated or not regulated at all.28 In fact, in a case that occurred shortly after the implementation of the 1967 Act it was ruled that one of the purposes of the Abortion Act was to eliminate procedures that were unhealthy.29 In addition, doctors are unlikely to refuse a pregnant woman’s request for an abortion within the 24 week time period because there is always the risk of a suit for negligence in respect of wrongful birth. For example in Rees v Darlington Memorial Hospital NHS Trust, a failed sterilization resulted in a successful negligence suit against the relevant medical practitioners.30 Ideally, reproductive autonomy should mean that a woman has the right to choose whether or not she wants to have an abortion or continue with a pregnancy without state interference. However, the state is not only obligated, but has an ‘interest’ in ‘the protection of life’.31 Under the Abortion Act 1967, the state generally recognizes and respects the reproductive autonomy of a woman when the pregnancy is 24 weeks or less as discussed above. At this point, the decision to remain pregnant or terminate a pregnancy with the approval or medical practitioners is regarded as a personal matter. For example, in Paton v British Pregnancy Advisory Service and Another a husband was denied injunctive relief in an attempt to stop his wife’s abortion which was certified by two medical doctors pursuant to the Abortion Act 1967.32 The court ruled that the court would not issue an injunction to enforce any of the marital responsibilities as they were private and personal matters. In other words, a woman’s decision to terminate a pregnancy under 24 weeks is strictly her decision and her husband or the father of her child has no right to attempt to prevent or interfered with her decision. Women’s reproductive autonomy is further fortified by what is known as the ‘morning after pill’ and the intra-uterine device (IUD). The morning after pill is administered within 72 hours of sexual intercourse for ensuring that ‘any fertilised ovum’ is not implanted ‘in the womb’.33 The IUD is also implanted soon after intercourse for a vastly similar effect.34 For all intents and purposes, the morning after pill and the IUD are early abortion treatments. Even so, doctors have been known to routinely prescribe these treatments without considering the provisions of the Abortion Act 1967. The Secretary of State for Health permits the morning after pill to be sold in pharmacies without a prescription and thus buttresses the reproductive autonomy of women within the 24 week period. In an action to reverse the Secretary of State for Health’s decision, the court refused noting that making the pill available was not an offence within the meaning of the Offences Against the Person Act 1861.35 It can therefore be concluded that an initial reading of the Abortion Act 1967, it appears as though a woman’s reproductive freedom is controlled by the medical profession and thus the state through legislating this authority to medical practitioners. However, the social ground together with on-going practice strongly indicates that until the foetus is 24 weeks old reproductive decisions remain with the pregnant woman. Thus, until the expiration of 24 weeks, woman have reproductive autonomy. Respect for the Life of the Foetus Respect of the life of the foetus centres on two opposing views about the time when the foetus is a life in being. On the one hand, it is argued that the foetus is a life in being the moment it is conceived. On the other hand, it is argued that the foetus is a life in being when it can be born alive.36 At this point the main concern is human rights, especially the right to ‘human dignity’.37 In this regard, the state’s interest in the foetus is an interest in ‘the potential life of the foetus’.38 The 24 week time limit therefore suggest that the potential life of the foetus is undetermined as it does not have a potential to be born alive prior to that point. Moreover, under English law, the foetus does not have a right to lawful action until such time as it is born and existing as a human being separate from its mother.39 The suggestion is therefore that the interests and well-being of the pregnant woman prevails over any potential life of the foetus, regardless of it how far along the pregnancy is.40 However, the Abortion Act 1967 acknowledges the potential of foetal life by setting the limit for legal abortion to 24 weeks or less. This provision therefore establishes a balance between a woman’s reproductive autonomy and respect for foetal life. It is unlawful to terminate a pregnancy in respect of a foetus that is older than 24 weeks. However, abortions after 24 weeks can be lawful if the health or life of the pregnant woman is seriously threatened by the pregnancy.41 It would therefore appear that the life of the foetus will always be subordinate to the life or health of the pregnant woman. Although seemingly unfair, this strikes a fair balance between the woman’s reproductive autonomy and respect for foetal life. This is because the life of the foetus at any time during the pregnancy is expressed in terms of potential. Although the foetus can be born alive in late pregnancy, the pregnant woman is a living human being. Balance is achieved because, after 24 weeks, abortion is only permitted as an emergency medical procedure. According to Hewson, abortions are quite rarely performed in the post-24 week term of pregnancy. When abortions are performed in the latter stages of pregnancy the pregnancy was usually wanted and it has been determined that the foetus will be born with significant handicaps that will cause grave suffering for the child and by extension, the mother and the family.42 Other rare late pregnancy abortions are performed to save the mother’s life and the pregnancy will not be forced on the woman since the common law does not force ‘good Samaritan’ obligations on individuals.43 The 24-week requirement does appear to balance the woman’s reproductive autonomy against the respect for the life of the foetus in that it reflects how much validity must be accorded an actual life against a potential life. The older the foetus is, the more viable the life of the foetus.44 At the same time, the ‘viability’ of the foetus must be measured against the actual life of the pregnant mother and her right to determine for herself whether or not she wants to endure a pregnancy.45 Legally, however, the foetus is not ‘a person’ and is therefore bereft of legal rights and therefore the limitations on abortion demonstrates that England’s abortion law at least attempts to protect the life of the foetus based on its potential, but not at the expense of an actual life.46 The prescribed time limit for a legal abortion reflects the respect for the life of the foetus articulated in the Infant Life (Preservation) Act 1929. By virtue of Section 1(1) of the Infant Life (Preservation) Act 1929 it is a felony to intentionally ‘destroy the life of a child capable of being born alive’ through ‘any wilful act’ that ‘causes a child to die before it has an existence independent of its mother’.47 In this regard, a foetus is capable of being born alive if the pregnancy is in its 28th week or more.48 Obviously, the viability of the foetus has been lowered by the Abortion Act 1967. Moreover, in balancing respect for the life of the foetus with the reproductive autonomy of the pregnant woman, the mere fact that the foetus is capable of being born alive will not suffice to criminalise an abortion which has been performed in late pregnancy ‘in good faith’ (Samanta and Samanta, 2011:191).49 In the pre-24 week period however, respect for the life of the foetus is subjugated almost entirely to the pregnant woman’s reproductive autonomy. At this stage of the pregnancy, the main question appears to be whether or not the pregnant woman wants to continue the pregnancy, despite the apparent strict limitations of the Abortion Act 1967. For example, where a minor expresses a wish to abort a pregnancy within the 24 week time period on the basis of its inconvenience, the court will defer to the reproductive autonomy of the pregnant minor on the basis of the social consequences of an unwanted pregnancy.50 It can therefore be argued that the Abortion Act 1967 is broadly interpreted to provide a fair balance between the pregnant woman’s reproductive autonomy and respect for the life of the foetus, but marking the period of pregnancy where the life of the foetus has greater significance. This period is 24 weeks. Any decision to terminate a pregnancy within this time period is consistent with the reproductive autonomy of the pregnant woman as social grounds permit the termination of an unwanted pregnancy. However any pregnancy outside of the 24 week period will only be terminated for medical reasons related to grave health and life concerns related to the pregnant woman. In other words, a pregnancy will not be terminated late in the pregnancy on social grounds. This reflects a greater respect for the life of the foetus and is based on the perception that as the pregnancy progresses the foetus becomes capable of being born alive and is therefore a life worth protecting provided the pregnancy does not pose a grave threat to the health and life of the pregnant woman. The foetus however, does not ‘have an enforceable right to life’, but the deliberate ‘destruction’ of a foetus capable of being born alive is a crime.51 Therefore, rather than protecting the life of the advanced stage foetus, England’s abortion law places constraints on reproductive autonomy when the foetus is viable by making provisions for criminal consequences. A late stage abortion will incur criminal consequences when the foetus is destroyed without a lawful excuse: protection of the life or health of the pregnant woman. Thus English abortion laws strikes a relative balance based on the actual life of the pregnant woman and the potential life of the foetus, but always leans more favourably toward actual life over potential life. Sheldon and Wilkinson raised a point that is relevant in considering whether or not English abortion law fairly balances the woman’s reproductive autonomy against the respect for the life of the foetus. Sheldon and Wilkinson argue that the Abortion Act 1967 does not achieve a fair balance because it gives wider autonomy to pregnant women who are pregnant with a disabled child and greater respect for the life of a foetus without a disability. In other words, the law discriminates in favour of the healthy child and the pregnant woman carrying an unhealthy child.52 In discriminatory cases of any kind a fair balance cannot be achieved as the rights to life in the case of the foetus and the right to reproductive freedom on the part of the woman are unevenly distributed. Regardless, the issue of discrimination is based on the viability of the foetus and only the most serious of disabilities are diagnosed during pregnancy. The disabilities would include life threatening consequences for the child or permanent injury which can put the pregnancy at great risk and can negatively impact the mental health of the pregnant woman and have severe consequences for the family. If doctors know in advance and during late pregnancy that a foetus will be born a vegetable the viability of the foetus is obviously not as high as the foetus that doctors have determined will be born healthy. The respect for the life of the foetus is therefore always based on the foetus’ potential for life and whether or not protecting its potential for life comes at a grave cost to the pregnant woman. It is up to the pregnant woman to determine whether or not she wishes to take that chance in late pregnancy. This is borne out by the pregnant woman’s right to forego life-saving treatment which can either end in her own death or the death of the infant.53 When examining the concept of respect for the life of the foetus it is necessary to acknowledge that life, under international human rights norm and most certainly under England’s abortion laws, do not begin until birth (Centre for Reproductive Rights, n.d.).54 Therefore, the pregnant woman’s life must prevail over the life of the foetus. England’s abortion law does reflect an interest in protecting the life of a foetus, but does not permit the foetus life to prevail over the life of the pregnant woman. In addition, England’s abortion law takes into account, not only the protection of the life of the pregnant female, but also women’s right to autonomy over their reproduction. This is reflected in the liberal interpretation of the conditions attached to early termination of a pregnancy. By placing more firm constraints on abortion in the latter stages of the pregnancy, England’s abortion law while curtailing reproductive autonomy, puts pressure on pregnant woman to make decisions on pregnancy at a time when the viability of the foetus is not an issue. By taking this approach, England’s abortion law strikes a fair balance between a woman’s reproductive autonomy and respect for the life of the foetus. Conclusion England’s abortion law fairly balances the reproductive autonomy of pregnant women and respect for the life of the foetus by reference to questions about the right to life. A pregnant woman’s right to life is broadly interpreted to include not only the right to forego a pregnancy at any stage of the pregnancy that puts her life at risk or threatens permanent injury, but the right to forego an early pregnancy if an unwanted pregnancy threatens the quality of her life. The distinction is made by evaluating the actual life of the pregnant woman and the viability of the life of the foetus. In this regard, England’s abortion law will not force a woman to continue a pregnancy in the early stages of a pregnancy if the baby is unwanted on social grounds. At this stage, the potential life of the foetus is incomparable to the life of the pregnant woman. As the foetus gains viability, the pregnant woman’s right to life, although superior to the life of the foetus, is only relevant if there is risk to her life or to prevent permanent injury to either the pregnant woman or the foetus. In other words, in respecting the life of the foetus in advanced pregnancy, England’s abortion law will not do so if doing so means sacrificing the life of the pregnant woman or the health of the foetus in medical terms. It can therefore be concluded that, under England’s abortion law, the social life of the pregnant woman is more important than the life of the foetus in early pregnancy. This is because under English abortion law, the foetus’ potential for life or its ability to be born alive does not exist at the early part of the pregnancy and therefore, there is no life in being to protect. The only life in being is the life of the pregnant woman. Once the pregnancy advances to a point where the foetus can be born alive, England’s abortion law places constraints on the woman’s reproductive autonomy as a means of providing some protection of the viable foetus, although the main concern is protecting the actual life of the pregnant woman. This is a fair balance to strike as it prohibits the wilful destruction of a foetus that can be born alive if such destruction is not necessary to save the life of mother or prevent permanent harm to the child or the mother. Bibliography Journal Articles Casas, L.B. ‘Woman and reproduction: From control to autonomy? The case of Chile,’(2004) 12(3) Journal of Gender, Social Policy & the Law,427-451. http://digitalcommons.wcl.american.edu/cgi/viewcontent.cgi?article=1315&context=jgspl Freedman, L. P. and Isaacs, S.L. ‘Human rights and reproductive choice,’ (Jan-Feb. 1993) 24(2)Studies in Family Planning, 18-30. http://www.law-lib.utoronto.ca/diana/fulltext/free3.pdf Hewson, B. ‘Reproductive autonomy and the ethics of abortion,’ (2001) 27 Journal of Medical Ethics, http://jme.bmj.com/content/27/suppl_2/ii10.full [Accessed 23rd February, 2015]. 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Skene, L. ‘Clinical ethics: An Australian lawyer’s response,’(2004)20 Journal of Medical Ethics, 408-409. http://jme.bmj.com/content/30/4/408.full Weinberg, J.K. ‘The politicization of reproduction,’(September 2013)5(1) Berkeley Journal of Gender, Law & Justice, 197-213. http://scholarship.law.berkeley.edu/cgi/viewcontent.cgi?article=1041&context=bglj West, R. ‘From choice to reproductive justice: De-Constitutionalizing abortion rights,’(2009) 118 The Yale Law Journal, 1394-1432. http://scholarship.law.georgetown.edu/cgi/viewcontent.cgi?article=1022&context=facpub Textbooks Gleeson, K. ‘The strange case of the invisible woman in abortion-law reform.’ In Jones, J.; Grear, A.; Fenton, R.A., and Stevenson, K. (Eds.) Gender, Sexualities and Law. (Oxon: Routledge, 2011) Ch. 16. https://books.google.com/books?id=g3erAgAAQBAJ&pg=PA216&lpg=PA216&dq=reproductive+autonomy,+foetal+life+and+the+abortion+act+1967&source=bl&ots=904Ym419Ao&sig=diQpof_JYMLX4KqETZ8m8P6zjTQ&hl=en&sa=X&ei=sA_oVNnQIYidgwTwtYOwCQ&ved=0CDkQ6AEwAw#v=onepage&q=reproductive%20autonomy%2C%20foetal%20life%20and%20the%20abortion%20act%201967&f=false Jackson, E. Regulating reproduction: Law, technology and Autonomy. (Portland, Oregon: Hart Publishing, 2001). https://books.google.com/books?id=8bfbBAAAQBAJ&pg=PA78&lpg=PA78&dq=women%27s+reproductive+autonomy+under+the+abortion+act+1967&source=bl&ots=q5URT0-G1u&sig=9ZmVDtDicH2stt999df44qkG0oo&hl=en&sa=X&ei=EjPoVNPUC8W0ggSZmoKwDw&ved=0CDAQ6AEwAw#v=onepage&q=women%27s%20reproductive%20autonomy%20under%20the%20abortion%20act%201967&f=false Jackson, E. Medical law: Text, cases, and materials. (Oxford, UK: Oxford University Press, 2013). https://books.google.com/books?id=1bCcAQAAQBAJ&pg=PA675&lpg=PA675&dq=abortion,+abortion+act+1967,+24+weeks,+life+in+being&source=bl&ots=BfMsdvJn8A&sig=_MGdRmeA1IoNGcJLvHYwZs_F5rI&hl=en&sa=X&ei=oKTqVKKMM4HmgwThn4GoDQ&ved=0CFoQ6AEwCQ#v=onepage&q=abortion%2C%20abortion%20act%201967%2C%2024%20weeks%2C%20life%20in%20being&f=false Samanta, J. and Samanta, A. Medical Law. (Hampshire: Palgrave MacMillan, 2011). https://books.google.com/books?id=h6ocBQAAQBAJ&pg=PA188&lpg=PA188&dq=abortion+act+1967,+respect+for+the+life+of+the+foetus&source=bl&ots=kqaBmhQaQ6&sig=asD8eeEGDiCaqihnM4_TTjAlyqo&hl=en&sa=X&ei=s0HrVKO7GITFggTR0oHgDA&ved=0CE4Q6AEwCTgK#v=onepage&q=abortion%20act%201967%2C%20respect%20for%20the%20life%20of%20the%20foetus&f=false Scott, R. Rights, duties and the body: Law and ethics of the maternal-fetal conflict. (Portland, Oregon: Hart Publishing, 2011). https://books.google.com/books?id=9fKIuN7EGQ4C&pg=PA188&lpg=PA188&dq=The+British+Abortion+Act+%281967%29+and+the+interests+of+the+foetus.&source=bl&ots=5g6oLLSsMw&sig=mk_kyEPZ050uvXJW4tTLCyOmQg8&hl=en&sa=X&ei=k9fqVKaVAcSmggS4hoTIBA&ved=0CDUQ6AEwBA#v=onepage&q=The%20British%20Abortion%20Act%20%281967%29%20and%20the%20interests%20of%20the%20foetus.&f=false Stauch, M.; Wheat, K. and Tingle, J. Text, cases and materials on medical law and ethics. (Oxon: Routledge, 2012) https://books.google.com/books?id=CavrPhg3BDgC&pg=PA390&lpg=PA390&dq=The+British+Abortion+Act+%281967%29+and+the+interests+of+the+foetus&source=bl&ots=2JnJjJvoo5&sig=I-HWb5pvg x6bNwSub2fUI-UHXfM&hl=en&sa=X&ei=kRPoVInPC8uqgwT_iYL4CA&ved=0CDgQ6AEwBQ#v=onepage&q=The%20British%20Abortion%20Act%20%281967%29%20and%20the%20interests%20of%20the%20foetus&f=false Cases Paton v British Pregnancy Advisory Service and Another [1978] QB 276. http://www.womenslinkworldwide.org/wlw/new.php?modo=observatorio&id_decision=460&lang=en R v Scrimaglia [1971] 55 Cr. App. R. R v Secretary of State for Health ex p. Smeaton [2002] EWHC 610. Re B (Wardship: Abortion)[1991] 2 FLR 426. Cited in Samanta, J. and Samanta, A. (2011). Medical Law. Hampshire: Palgrave MacMillan. https://books.google.com/books?id=h6ocBQAAQBAJ&pg=PA188&lpg=PA188&dq=abortion+act+1967,+respect+for+the+life+of+the+foetus&source=bl&ots=kqaBmhQaQ6&sig=asD8eeEGDiCaqihnM4_TTjAlyqo&hl=en&sa=X&ei=s0HrVKO7GITFggTR0oHgDA&ved=0CE4Q6AEwCTgK#v=onepage&q=abortion%20act%201967%2C%20respect%20for%20the%20life%20of%20the%20foetus&f=false Rees v Darlington Memorial Hospital NHS Trust [2003] UKHL 52. http://www.publications.parliament.uk/pa/ld200203/ldjudgmt/jd031016/darl-1.htm Statutes Abortion Act 1967. Infant Life (Preservation) Act 1929. Miscellaneous Publications Bristow, J. ‘Britain’s abortion law: What it says, and why,’ (2013) British Pregnancy Advisory Service, 1-29. http://www.reproductivereview.org/images/uploads/Britains_abortion_law.pdf [Accessed 23 February 2015]. Centre for Reproductive Rights. ‘Whose right to life?: Women’s rights and prenatal protections under human rights and comparative law,’ (n.d.)1-18. http://www.despenalizacion.org.ar/pdf/publicaciones/WHOSE-RIGHT-TO-LIFE.pdf [Accessed 23 February 2015]. Dixon, R. and Nussbaum, M. ‘Abortion, dignity and a capabilities approach,’ (March 2011)Chicago Public Law and Legal Theory Working Paper No. 345:1-20. http://www.law.uchicago.edu/files/file/345-rd-mn-abortion.pdf Read More