Abortion In India

Project assignment submitted as partial

fulfilment of the Course Requirement for the
subject of

Constitutional Law-II

Submitted by:
Gaurob Marik
Roll No. 52
Semester - IV

Dr. Ram Manohar Lohia

National Law University
LUCKNOW

Acknowledgment
I take this opportunity with great pleasure to thank faculty Incharge of Constitution, my friends and library staff members who
have supported me in the completion of this project work. I would
like to extend my heartfelt gratitude to my faculty in-charge of
above mentioned subject for his vital encouragement and support.
He has given me the opportunity to point out the purpose and
comprehensiveness of this project work.
Finally, I would like to express my heartfelt thanks to my parents
who made all things possible.

Index

Introduction

India in Reality

Present Deliberation

A Complex Issue: Pro-life vs. Pro-choice

Laws of Abortion in Other Countries

8
12

A Balanced Approach

12

Abortion in Comparison to Euthanasia

13

Conclusion

14

Bibliography

16

Introduction
Abortion remains a sensitive matter in most countries, receiving
considerable international attention not only as a public health
concern but also as an ethical, moral and religious issue. This
paper deals with the grim realities concerning abortion in India,
the present debate which is inclusive of pro-choice and pro-life
issue, followed by the abortion laws in different countries and
Indias Balanced Approach, lastly my take on the issue of
abortion in India.

India in Reality
Indias pioneer in legalizing induced abortion was incorporated
through the Medical Termination of Pregnancy Act, 1971, under
which a woman can legally have an abortion if the pregnancy
carries a risk of grave physical injury or endangers her mental
health, if it is the result of contraceptive failure in a married
woman, if it is the consequence of rape, or if it is likely to result in
the birth of a child with physical or mental abnormalities.
According to the Ministry of Health and Family Welfare (MOHFW), about 5.4 lakh
MTPs were performed in the country in 1996 97, an estimated 6.7 million abortions
per year are performed in other than registered and government recognized
institutions, often by untrained persons in unhygienic conditions. According to
the Consortium on National Consensus for Medical Abortion in
India, every year an average of about 11 million abortions take
place annually and around 20,000 women die every year due to
abortion related complications.1 Most abortion-related maternal
1

"Introduction". Consortium on National Consensus for Medical Abortion in

India.
4

deaths are attributable to illegal abortions.2 In the following table

Number of abortions reported includes legal reported induced
abortions.3

Year
Number of
abortions
reported

1972 1975 1980 1985 1990 1995 2000

2430 2141 3884 5837 5812 5709 7231

0

97

05

04

15

14

42

Abortion was liberalized in India after the 1971 MTP Act came into
effect on 1 April 1972, according to which a pregnancy may be
terminated within 20 weeks of gestation. India was one of the first
countries during 1970s to have such a liberal to have such liberal
abortion laws. Before 1972, abortion was permitted only if it was
necessary to save the life of the woman. Now it is also allowed on
grounds of preserving her mental or physical health, as well as in
cases of pregnancy due to rape, incest or contraceptive failure.
However, it is illegal if performed just because a woman (or some
other person) requests it, or if it is sought only for social and/or
economic reasons. The Indian government has also repeatedly
emphasized that MTP should not be viewed as a method of family
planning or of reducing the national birth rate.
Unfortunately Legalizing abortion has not ensured its accessibility
to the poor nor been an effective method for curtailing population
growth. Moreover, abortion is still one of those issues in womens
life which is buried in silence. In a country like India, womens
http://www.aiims.edu/aiims/events/Gynaewebsite/ma_finalsite/introduction.html.
"Current status of abortion in India". Consortium on National Consensus for Medical
Abortion in India.
http://www.aiims.ac.in/aiims/events/Gynaewebsite/ma_finalsite/report/1_1_1.htm.
3
Historical abortion statistics, India Historical abortion statistics, India
2

health is given very low priority and their lack of control over
family resources denies them access to health care in general and
abortion in particular. In addition to being considered dangerous to
womens

health,

abortion

is

also

deemed

to

be

socially

unacceptable.
Studies in many developed and developing countries show that
even where abortion is legal, women are reluctant to talk about it.
In India, its incidence is always under reported, perhaps because of
the guilt or the moral stigma attached with it.
Although abortion is legal, it is estimated that four million Indian
women a year still resort to illegal abortions because of social
taboos, misconceptions about the law, and the lack of skilled
practitioners and medical facilities. Research has also shown that
the ratio of illegal to legal abortions is highly skewed there are
many more illegal abortions than the legal ones. Because of illegal
abortions, there are between 15,000 to 20,000 abortion related
deaths in the country every year, mainly among married,
multifarious women. But even generally, deaths due to induced
abortion are quite high; for example, in Maharashtra in 1995, 17.6
% of maternal moralities were due to induced abortion .It is
therefore evident that legislation of abortion is a necessary but not
sufficient condition for reducing the number of unsafe abortions.
A large proportion of abortions are now cited as falling under a
special category that was almost non existent at the time of
framing of the Act. This category is sex determination followed by
abortion of the female foetus. In such cases, it is not the pregnancy
but its outcome that is unwanted. The first sex- selective abortion
was

documented

in

India

in

1970s,

with

the

advent

of

amniocentesis. Though chromosomal analysis of amniotic fluid was

developed to diagnose sex linked genetic disorders, it almost
immediately began to be used in genetic clinics for determining the
6

sex of the foetus, with the sole purpose of circumventing the birth
of girls. The 2001 census jolted the govt and the civil society alike
an alarming decline in the juvenile sex ratio from 971 in 1981 to
945 in 1991 and 927 in 2001 made national as well as international
headlines.
Giving or taking prenatal tests solely to determine the sex of the
foetus is being criminalized by the Indian parliament. Female
children are still widely considered to be a social and financial
liability in a country where the dowry system is still a part of
marriage. The prenatal tests have been used to detect female
foetuses, which are then aborted. Under Indian law, ending a
pregnancy only because a foetus is female has already been
outlawed, although the practice is common. Poor women who
cannot afford the cost of either prenatal testing or abortion often
resort to female infanticide.
Despite the fact that it is now more than thirty years since MTP
was legalized in India, women still feel shy of speaking about it.
This has proved to be one of the major stumbling blocks in
gathering information about the extent of foetal wastage in general
and induced abortions in particular. There are a few clinic based
studies that provide information about abortions, but since the
sample used is very selective, it is difficult to extract information
about the processes and patterns associated with abortion from his
data. It is this lack of reliable data which necessitates research on
abortion that can shed light on the pathways leading to abortions
well as on the associated underlying factors, including quality of
care and cost.

Present Deliberation

The Nikita Mehta case has given rise to a raging debate on

abortion laws in the country. The key issue is whether the statutory
time limit for abortion must be increased from the currently
permitted twenty weeks of gestation to twenty four weeks or
above? The answer is not easy to arrive at. The issue involves
complex questions of law, morality, theology, medicine and
philosophy. This debate only deals only with a part of the whole
issue of abortion in India.
A pregnancy when carried to term may stretch to about forty
weeks. The Medical Termination of Pregnancy Act, 1971 permits
abortion to be performed only when the pregnancy poses a risk to
the life of the pregnant woman, or, of grave injury to her physical
or mental health, or, when there is a substantial risk of the child
being born with physical or mental abnormalities so as to be
seriously handicapped.

A registered medical practitioner may terminate the pregnancy up

to twelve weeks of gestation but where the period is between
twelve to twenty weeks, the opinion of two registered medical
practitioners is required. The limit of twenty weeks may be crossed
only when the procedure is performed to save the life of the
woman. Importantly, pregnancy that results from rape or failure of
a contraceptive device between a married couple is viewed as
causing grave injury to the mental health of the woman.

In the Nikita Mehta case the gestational period had progressed

much beyond the prescribed period and was past twenty five
weeks. The petitioners pleaded that the defect in the heart of the
unborn child was detected at a late stage. They expressed their
inability to bear the psychological and monetary burden of giving
birth to a child that may suffer from severe health problems. The

anguish of such parents is understandable. It may neither have

been an easy life for the child on birth nor a comfortable situation
for the parents to raise a child with such a disability.
In the Nikita Mehta case, the Mumbai high court held that no
categorical opinion of experts had emerged to state that the child
would be born with serious handicaps. The court thus denied
recourse to medical termination of the pregnancy and an opinion
emerged that terminating the life of a viable unborn on grounds of
possible handicap is akin to mercy killing.
The 38-year-old abortion law was later challenged in the Supreme
Court which sought a response from the government for continuing
with a provision prohibiting termination of pregnancy after 20
weeks even if there was a fatal risk to the mother and the foetus.

A Complex Issue: Pro-life vs. Pro-choice

Pro-life activists are those who believe that abortion is not
acceptable because it kills a foetus, and pro-choice supporters
conceive that women have a right to choose abortion. The issue is
complicated by questions of what to do when the mothers life is
threatened by the pregnancy and whether the right of women
should be given precedence over unborn child rights or vice-versa.
Certain pro-life supporters may believe that abortion is not
acceptable at all times in all circumstances, while others may
believe that abortion is acceptable in extreme cases, such as when
the mothers life is threatened by pregnancy. On the other hand,
among pro-choice supporters, there are different opinions as to
who should make the final decision.

For arriving to a concrete decision to this complex issue a

method can be incorporated. The whole time period starting
from pre-pregnancy period till the later stages of pregnancy,
can be divided into following four stages1. The Stage of Pre-inception of an Embryo - It is that stage
which prevails just before a woman gets pregnant. At this stage,
she has the freedom to decide not to have a child at a certain point
of time as well as to choose to remain childless. This right is
consequently an integral part of womens reproductive freedom.
Such an interpretation of Article 16(1)(e) was given by Convention
on the Elimination of All Forms of Discrimination against Women,4
in its session in 1993:5 :
Womens right to full and free exercise of their reproductive
functions, including the right to decide whether to have children or
not, must not be limited by spouse or government.
CEDAW has been ratified and adopted by India and has also been
read into the fundamental rights provided under Articles 14, 19
and 21 of the Constitution.6
Article 21 of the Constitution of India provides thatNo person shall be deprived of his life or personal liberty except
according to procedure established by law.
The right to privacy has several aspects. One such aspect is the
right to procreate. This is also known as the right of reproductive
autonomy. The right to use condom is a right that fall within the
ambit of right to privacy7.

Article 16(1)(e) of CEDAW :

States Parties shall take all appropriate measures to eliminate discrimination against women
in all matters relating to marriage and family relations and in particular shall ensure, on a
basis of equality of men and women: The same rights to decide freely and responsibly on the
number and spacing of their children and to have access to the information, education and
means to enable them to exercise these rights
5
UN Doc. E/CN.6/1993/CRP.2, 25 February 1993
6
Vishaka v. State of Rajasthan.
7
Discussed in M.P Jain, Indian Constitutional Law,

10

2. The Stage of Post-Inception of Embryo- At this stage

she is already pregnant and during this time-period woman
enjoys her right to choose abortion. Therefore, its upon her
discretion to decide whether she wants to carry forward with
the pregnancy or not. At this stage, the right of women
prevails and the state must not interfere with her choice.
Right to abortion is also included in the right to privacy available
under Article 21 of the Constitution of India. Further in Jane Roe v.
Henry Wade8, the US Supreme Court has ruled that the right to
have an abortion is a fundamental constitutional right to privacy of
the woman. In a concurring opinion, Stewart, J. noted that:
We recognized the right of the individual, married or
single, to be free from unwarranted governmental
intrusion into matters so fundamentally affecting a
person as the decision whether to bear or beget a child.
That right necessarily includes the right of a woman to
decide whether or not to terminate her pregnancy.
3. The Stage Between Twelve to Twenty Weeks of Gestation
-Every woman has the right to choose, but it is time specific. She
may exercise her right to decide whether or when she will conceive
a child. However, once conception has occurred, a new separate
human being is in a process of creation, who has the same right to
life as that of the woman. The demarcating line is till 12 weeks of
pregnancy, until which the womens right to choose exist but
beyond that gradually the unborn child right starts taking place
and the womens rights starts to fade. Therefore, the period
between twelve to twenty weeks can be said to be a transition
phase. That is the reason why in Indian context only one registered
medical practitioner is required to terminate the pregnancy up to
twelve weeks of gestation but where the period is between twelve
to
8

twenty

weeks,

the

opinion

of

two

registered

medical

410 U.S. 113

11

practitioners is required and when the limit of twenty weeks is

crossed then procedure is performed only to save the womans life.
In an American case decided in 1973 wherein the court held that
an expecting woman has absolute right to privacy in respect of her
body till the first twelve weeks of pregnancy. At this stage the state
must not interfere with her decision about continuation or
termination of pregnancy while the fetus is but a part of her body.
Between twelve and twenty weeks the state may place limited
restrictions to permit abortions only when direly necessitated, for
example to save the life of a pregnant woman or on eugenic
grounds to prevent birth of severely malformed babies. But where
the period of gestation crosses twenty weeks the state may step in
to curtail abortions completely on grounds of compelling state
interest to protect and preserve potential life for the future of the
society, except in cases where the mothers life is at stake.
4. The stage of 20th week of gestation and above- Her right to
choice ceases to exist the moment 20 th week of gestation accesses.
Now the significant question that arises is why the demarcation is
at twenty weeks? The answer lies in the fact that the baby becomes
viable at this stage. In other words, the baby is no longer
indispensably dependant on its mothers body and stands a chance
of survival upon delivery, albeit with suitable aids at this premature
stage. As it grows, it becomes more and more capable of
independent survival and from seven months of gestation onwards,
the chances of its survival upon birth become bright. In addition to
state interest, the interests of the fully formed unborn child at this
stage become noteworthy. The unborn find explicit or implicit
protection

through

many

international

and

national

laws .Paragraph 9 of the preamble of the Convention on the Rights

of the Child states that "bearing in mind that, as indicated in the
Declaration of the Rights of the Child, "the child, by reason of his
physical and mental immaturity, needs special safeguards and care,

12

including appropriate legal protection, before as well as after

birth.''
It was held in T.S. Srinivasan v. Commissioner of Income-tax,
Madras9 :
That a child in embryo is to be considered as a person in
existence for certain purpose is a rule not peculiar to Hindu
Law but obtains in other systems of jurisprudence as well.
Under the law a person is one to whom the law attributes a
capacity to possess rights and perform duties.
Famous Jurist Salmond was of the opinion that though the dead
possess no legal personality, it is otherwise with the unborn. 10 In
the case of T.S. Srinivasan v. Commissioner of Income-tax, Madras11
the court upheld the same view as Salmond in his Jurisprudence. 12
The Indian legal system has conferred on the unborn child various
rights under different statutes.13 Hence an embryo is a person
capable of rights and duty. Thus it is protected under Article 21 of
the Constitution of India.
In Davis v. Davis14, it was held that the embryos were, in law,
persons, such that they manifest best interest of the child, in vitro,
that they be made available for implantation to assure their
opportunity for live birth. In Elliot v. Joicey15, it was said that "in all
matters affecting the fetuss interest, the unborn child in uterus
should

be

deemed

to

be

already

born"

The State is under obligation to under Article 21 not only to protect

the life of an unborn child from arbitrary and unjust destruction but
9

AIR 1962 Mad 146

P J Fitzgerald, Salmond on Jurisprudence, Ed. 12th, Universal Law Publishers, 2004
11
AIR 1962 Mad 146
12
1957 Ed., at page 350, 353 and 354
"A person is any being whom the law regards as capable of rights or duties. Any being that is so capable is a person whether a
10

human being or not...There is nothing in law to prevent a man from owning property before he is born. His ownership is
necessarily contingent indeed, for he may never be born all but it is nonetheless a real and present ownership. A man may settle
property upon his wife and children to be born of her or he may die intestate and his unborn child will inherit his estate..........A
child in its mother's womb is for many purposes regarded by a legal fiction is already born in accordance with the maxim
naciturus pro jam natro habetur.
13

Sec 20 of Indian succession act 1920, Sec 13 of Transfer of Property Act 1882.
842 Sw 2d 588
15
1935 SC (HL)57: (1935) AC 209.
14

13

also not to deny it equal protection under Article 14 of the

Constitution16.Absolute Right to abortion will lead to destruction of
unborn child arbitrarily.

Laws of Abortion in Other Countries

In many countries religious and political groups refer to
abortion as murder, while womens rights advocates insist it
forms part of a womans fundamental right to have control
over her body. Canada, Korea, China, Germany, France and
several other European countries have comparatively liberal
laws on abortion. Canada goes to the extent of not interfering
with the issue at all and leaves it entirely to the woman and
her physician. The woman is perceived as having complete
liberty upon her person and the foetus is seen as a part of her
body, acquiring the status of a person only after birth. Korea
permits abortions till twenty-eight weeks but spousal consent
is mandatory for married women. The Abortion Act, 1967 of
U.K. permits abortions till twenty four weeks but there is no
upper limit if the pregnancy poses a threat to a womans life
or if the foetus is likely to be born with severe physical or
mental

deformity.

There are countries that place more severe restrictions upon

abortions. While El Salvador and Chile have endorsed a
complete ban on abortions, Afghanistan, Bangladesh, Brazil
and a few others permit abortion only in cases of rape.

A Balanced Approach

16

AIR 1996 Journal Section 136 at p. 140

14

The right of reproductive autonomy which falls within the ambit of

the right to privacy have been very widely discussed in the U.S.A. in
Roe v Wade

17

, the U.S Supreme court has ruled that the right to

have an abortion is a part of fundamental constitutional right of

privacy of the woman and the State can interfere with such a right
only to promote some compelling interest of the State. This right to
abortion is a qualified one that must be balanced against competing
sate interests, namely maternal health and foetal life.
In India, however, such polarisation of views has been absent, in
comparison to other countries, India has chosen a middle path
instead of a this-way-or-that-way approach. Rightly so perhaps ,
given the sensitivity of the issue. A Balanced Approach appears
suitable; a balance between the respective interests of the woman,
the unborn, her
family and the state.
The balance approach is immaculately discussed in an American
case18 decided in 1973 wherein the court held that an expecting
woman has absolute right to privacy in respect of her body till the
first twelve weeks of pregnancy. Between twelve and twenty weeks
the state may place limited restrictions to permit abortions only
when direly necessitated, for instance, to save the life of a pregnant
woman or on eugenic grounds to prevent birth of severely
malformed babies. But where the period of gestation crosses
twenty weeks the state may step in to curtail abortions completely
on grounds of compelling state interest to protect and preserve
potential life for the future of the society.

Abortion in Comparison to Euthanasia

17
18

410 U.S. 113, 93 S. Ct. 705, 35 L. Ed. 2d 147 (1973).

Roe v. Wade, 410 U.S. 113, 93 S. Ct. 705, 35 L. Ed. 2d 147 (1973).

15

The defence of poor quality of life is a weak defence. Is the right

to choice, taking on a form of euthanasia on the unborn? When we
affirm life, we affirm ourselves. Are we not worthy of life and of
human care and compassion, when we are chronically ill, infirm
and aged, crippled or paraplegic? If we condemn the imperfect
child, we are denying our own right to life.
Even if we go by conservative estimates that 7-10 per cent of
Indias population is disabled, approximately 7-10 million, an
overwhelming majority of this population live in distressed
circumstances. According to the Indian Association of Muscular
Dystrophy, there are 8,000 patients with MD living in Andhra
Pradesh and about four lakh in India. Besides, there are lakhs of
people with spinal cord injury who are in similar distress as
those with MD elderly PWDs and those with terminal ailments
like HIV/AIDS or cancer. The demand for mercy killing is more of a
symptom rather than a real issue.
At this point, it might be pertinent to briefly understand mercy
killing in the Indian context, before arriving at a conclusion. Mercy
killing is defined as the intentional termination of the life of one
human being by another. This could be done either through a
lethal injection or withdrawal of the life support system or
medication. Mercy killing is legal in only six countries namely
Belgium, Luxemburg, The Netherlands, Switzerland, the US state
of Oregon and Thailand.
The Indian Constitution does not consider the Right to Die as a
fundamental right. However, for the first time in 198719, the judges
at the Bombay High Court felt that the desire to die is merely
uncommon but not unnatural. They listed several circumstances in
which people may wish to end their lives, such as disease,
unbearable condition of living, if they have a deep sense of shame
19

State of Maharashtra vs Maruti Shripathi Dubal case

16

or disenchantment with life. This being said there have been

numerous instances where judges have simply overruled the plea of
the right to die. The recent incident being that of 25-year-old
Venkatesh, who petitioned the Andhra Pradesh high court in 2004 ,
seeking mercy killing while on life-support at a Hyderabad hospital.
Venkatesh too was suffering from Muscular Dystrophy.
Therefore, till the time right of women is in question abortion of an
unborn, which is again an act euthanasia, can still be committed as
the foetus is after all a part of her body. But beyond that it should
be termed as mercy killing.

Conclusion
If the question is put forward to me whether there should be
increase in the limit of abortion in India or not ? Then drawing
conclusion from the above arguments I would right away reject the
plea of increasing the limit of abortion from 20 to 24 weeks.
In U.K an all-party group of MPs had campaigned to reduce the
maximum age at which a baby can legally be aborted from 24 to 20
weeks. Change is urgently needed, they say, because medical
science has advanced so far since the limit of 24 weeks was set in
1990, that thousands of babies born at less than 24 weeks
gestation, who would probably have died then, now survive. Armed
with this evidence, campaigners argue that allowing a baby over 20
weeks to be aborted, unless the mother is in danger or the child
grievously malformed, is nothing less than child cruelty. Recent
polls show three quarters of women in U.K favor lowering the 24week limit. In France and Germany, appeal has been made to make
it within 12 weeks.
When developed countries like U.K, France, Germany, etc are
campaigning for lowering the abortion limit then why should India

17

try to go against the tide in increasing the limit of abortion .Rather

I would suggest, taking into consideration the ground realities in
India, the limit of abortion should be brought down even from the
current 20 week margin so that female infanticide, death due to
abortion, and number of abortions, etc. can avoided to certain
extent..

The Abortion Act, 1967 of U.K. permits abortions till twenty four
weeks but there is no upper limit if the pregnancy poses a threat to
a womans life or if the foetus is likely to be born with severe
physical or mental deformity. Keeping in view the Nikita Mehta
case, it will be noteworthy to amend the MTP Act in accordance
with the Abortion Act of U.K. only difference will be that the
abortion limit will be till twenty weeks.
Every day nearly 48,000 abortions take place in India. , every year
an average of about 11 million abortions take place, around 20,000
women die every year due to abortion related complications,[1] The
2001 census showed an alarming decline in the juvenile sex ratio
from 971 in 1981 to 945 in 1991 and 927 in 2001. Most of these are
not cases of detected fatal abnormalities but unwanted
pregnancies. When the real picture of abortion in India is seen at
large then this present debate on Nikita Mehta case seems to be a
miniscule issue. At macroscopic level, the Nikita Mehta case can be
safely booked under exceptional cases. To legalize abortions at 24
weeks from the existing 20 weeks will result in killing off even
more babies.
In Mother Teresa words: If we accept that a mother can kill even
her own child, how can we tell other people not to kill one
another?

18

Bibliography

Leela

Visaria

and

Vimala

Ramachandran

Abortion in India Ground Realities, Routledge

P J Fitzgerald, Salmond on Jurisprudence, Ed. 12th, Universal

Law Publishers, 2004

M.P Jain, Indian Constitutional Law.

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21