A STUDY ON THE REPRODUCTIVE RIGHTS OF WOMEN WITH EMPHASIS ON INDIA

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“There is no freedom, no equality, no full human dignity and personhood possible for women until they assert and demand control over their own bodies and reproductive process…The right to have an abortion is a matter of individual conscience and conscious choice for the women concerned.”[1]

-Betty Friedan.

For generations, women have fought for the freedom to choose when it comes to their reproductive health. Due to moral, ethical, and religious reasons, these rights have always been a contentious issue. Is it true that reproductive rights only refer to the ability to reproduce? Is the problem intrinsically related to the many debates about women’s reproductive rights? Women appear to be distinguished from men by their ability to reproduce. Do women, on the other hand, have control over their own reproduction? Do women have the choice to choose whether to have children, when to have them, and how many they have? Do women have access to birth contraception that is both effective and safe? Is it true that women have the right to a safe abortion? Is it possible to divorce sexuality from reproduction? The answer to most of these questions is ‘NO’. The formation of the women’s health movement in several parts of the world in the early 1970s was sparked by a resounding ‘NO’ in response to many such concerns. It originated as modest ‘awareness-raising’ groups, which began by informing women about the functions of their bodies and subsequently expanded into multi-faceted campaigns that have had a considerable impact on health legislation in many nations.

When a woman’s bodily integrity is violated, her body is invaded against her will, and her choices are based on social standards rather than personal preference, she is unlikely to participate actively in decision-making, whether at the micro individual level or at the macro societal level. The women’s health movement around the world has advocated women’s right to voluntary maternity through access to safe contraception and abortion services in an effort to reclaim women’s control over their own fertility and open doors for autonomy and decision-making in other areas of life.

Human rights are those rights that should be available to everyone without any type of discrimination. The foundation of freedom is the recognition of all members of the human family’s inherent dignity and equal and inalienable rights. The right to life is a human’s most important and fundamental human right, from which no exceptions can be made. It is unassailable. The arbitrary deprivation of life is prohibited by Article 6(1) of the International Covenant on Civil and Political Rights. However, there are several contentious concerns surrounding this greatest privilege. The right to abortion is one of these issues. It is considered that, among other rights, every mother has the right to abortion, which is a universal right. However, the rights of the mother must be balanced against those of the unborn child.

Abortion is one of the most confrontational ethical issues because it involves the termination of a human life. In general, traditional arguments for and against abortion are guided by legal and religious arguments, respectively. Those in favour of abortion make the case that abortion represents a woman’s “right to choose” whether to continue or terminate her pregnancy. Antiabortionists typically use religion as the linchpin of their collective opposition to abortion. Previously, the right to abortion was not granted, and society was highly opposed to it. Terminating a pregnancy was referred to as “murdering the foetus.” However, as time and technology have progressed, most countries now recognise this right, following the historic Roe vs Wade[2] decision by the US Supreme Court. However, there are still many who oppose it, and some believe it should be made illegal.

What is Abortion?

Abortion is the removal or expulsion of an embryo or foetus from the uterus, which results in or causes the death of the embryo or foetus. This can happen naturally as a miscarriage, or it can be intentionally caused through chemicals, surgery, or other methods. Commonly, “abortion” refers to an induced procedure at any point in the pregnancy; medically, it is defined as a miscarriage or induced termination before twenty weeks gestation, which is considered nonviable.

Induced abortions have been a subject of debate and controversy throughout history. An individual’s personal viewpoint on complicated ethical, moral, and legal issues is inextricably linked to his or her value system. The morality of induced abortion and the ethical limit of the government’s legitimate jurisdiction are two aspects of a person’s abortion stance. Individual rights, such as the right to life, liberty, and the pursuit of happiness, support a woman’s right to have an abortion. Reproductive rights are widely acknowledged as essential for furthering women’s human rights and supporting development. Governments all throughout the world have acknowledged and vowed to improve reproductive rights to unprecedented levels in recent years. Government commitment to promoting reproductive rights is reflected in formal laws and programmes. Every woman has the complete right to control her body, which is sometimes referred to as bodily rights.

The Case of Roe v. Wade

The case of Roe v. Wade went down in history as one of the most politically significant Supreme Court decisions, reshaping national politics, splitting the nation into “pro-choice” and “pro-life” camps, and inspiring grassroots activism. This is a landmark decision by the United States Supreme Court establishing that most anti-abortion laws violate a constitutional right to privacy, effectively overturning all state laws outlawing or curtailing abortion that were inconsistent with the decision. The plaintiff, Jone Roe, wanted to terminate her pregnancy because she claimed it was the result of rape. The decision, based on the current state of medical knowledge, established a trimester system that attempted to balance the state’s legitimate interests with the individual’s constitutional rights. The Court ruled that the state cannot constrain a woman’s right to an abortion during the first trimester, that the state can regulate abortion procedures during the second trimester “in ways that are reasonably related to maternal health,” and that in the third trimester, demarcating the viability of the foetus, the state can choose to restrict or even prohibit abortion as it deems fit.

In response to Roe v. Wade, several states passed abortion-restricting laws, such as laws requiring parental consent for minors to obtain abortions, parental notification laws, spousal consent laws, spousal notification laws, laws requiring abortions to be performed in hospitals rather than clinics, laws prohibiting state funding for abortions, and laws prohibiting most very late term abortions. In a long series of cases spanning the mid-1970s to the late 1980s, the Supreme Court overturned several state restrictions on abortion.

Following the Roe v. Wade decision, several European and American countries began to legalise abortion. Since the 1970s, numerous countries have liberalised their abortion regulations during the last thirty years. The Roe judgment was later modified by the US Supreme Court in Planned Parenthood v. Casey[3], which now links the legality of abortion laws to the viability of the foetus rather than the rigid third trimester standard established in the Roe case.

Stance by other countries on Abortion

Abortion continues to be one of the most controversial issues of women’s rights. In fact, it was the fight for abortion legalisation that sparked the women’s health movement in the United Kingdom and the United States. Nonetheless, abortion is still illegal in many countries around the world, including in the West’s industrialised countries, or is conditional, i.e. women can have abortions only in the event of rape or if the mother’s life is seriously threatened. Clandestine/illegal abortion is a leading cause of serious health complications and even death in women all over the world. The abortion debate stems from widely divergent views on when ‘life’ begins. ‘Prolife’ advocates, or those who oppose women’s right to abortion, argue that ‘life’ begins at conception and that killing a foetus is murder. ‘Pro-choice’ advocates, or those who advocate for women’s right to abortion, argue that ‘life’ begins only when the foetus is ‘viable,’ or capable of surviving outside the mother’s body. The conflict of interests between the right of the woman to choose whether or not to proceed with the pregnancy and the interests of the foetus, which ‘pro-lifers’ claim is an entity with a right to life, is inherent in this debate.

Abortion has social, religious, economic, and political implications. Its impact on society can be viewed in both a positive and negative light. During the early stages of developing abortion policy, Western civilisations were opposed to the practise. By the nineteenth century, many countries had passed laws prohibiting abortion. It wasn’t until the late twentieth century, after many awareness campaigns, that some countries, including the United States, began to legalise abortion.

Roe v. Wade has become almost synonymous with the United States and abortion laws. According to it, medical judgement can be exercised in light of all factors, including physical, emotional, psychological, and familial factors, giving the attending physician the space he needs to make the best medical decision. The gestation period ranges from eight to twelve weeks. Twenty-two states have prohibited the use of procedures lasting between 13 and 25 weeks. Some states, such as Alabama, prohibit abortion during the entire pregnancy. Many states limit access through a variety of means, including regulations targeting abortion providers and mandatory delays. Some states are enacting increasingly stringent bans, including pre-viability bans, which are being challenged in court. Arkansas, Georgia, Louisiana, Kentucky, Mississippi, Missouri, Ohio, Utah, and Alabama are among the nine states that have banned abortion at various stages of pregnancy in 2019. (which passed a total abortion ban). None of these laws are currently in effect, and the Center for Reproductive Rights and its partners are working hard to keep them that way.

In Brazil, Legal abortions are permitted in cases of rape and when there are no other options for saving a pregnant woman’s life. Women and girls who terminate a pregnancy under any other circumstances face a prison sentence of up to three years. According to media reports, the courts registered over 300 abortion-related cases against women in 2017, many of which were reported by health professionals from whom women were seeking MTPs outside of the system.

Developing countries are responsible for 97 percent of all unsafe abortions. More than half of all unsafe abortions take place in Asia, with the majority taking place in South and Central Asia. In Latin America and Africa, the majority of abortions (roughly three out of four) are unsafe. In Africa, nearly half of all abortions take place in the most dangerous conditions. The stigma associated with abortion, as well as the lack of access to safe, affordable, timely, and respectful abortion care, endangers women’s physical and mental well-being throughout their lives. Inaccessibility to quality abortion care risks violating a number of women’s and girls’ human rights, including the right to life; the right to the best possible physical and mental health; the right to benefit from scientific progress and its realization; the right to freely and responsibly decide on the number, spacing, and timing of children; and the right to be free from torture, cruel, inhuman, and degrading treatment and punishment. Every year, unsafe abortion accounts for 4.7–13.2 percent of maternal deaths. It is estimated that 30 women die in developed countries for every 100,000 unsafe abortions. In developing countries, that figure rises to 220 deaths for every 100,000 unsafe abortions.

Abortion in India

Abortions have been around for a long time. However, it has received attention at various points in history for a multitude of reasons, some in support of it, but often in opposition to it. Abortion is primarily a health concern for women, but it is increasingly governed by patriarchal interests, which frequently limit women’s freedom to seek abortion as a right. Abortion practise has become a critical issue in recent years, with the entire focus of women’s health being on her reproduction, in fact preventing or terminating it. Given the official perspective of understanding abortion in the context of contraception, a review of abortion and abortion practise in India is necessary. In India, there are numerous statues that address this issue. Now we will go over Indian law in order to determine the position of both the mother and the unborn child. Miscarriage is punishable under Section 312 of the Indian Penal Code, 1860 (IPC). It reads as follows:

312. Causing miscarriage. – whoever causes a woman with child to miscarry, shall, if such miscarriage be not caused in good faith for the purpose of saving the life of the women, be punished with imprisonment of either description for a term which may be extended to three years, or with fine, or with both; and if the woman quick with child, shall be punished with imprisonment of either description for a term which may extend to seven years, and shall also be liable to fine.[4]

This section applies to a woman who causes herself to miscarry. Section 312 of the Code punishes the person who causes a woman’s miscarriage. The provision’s explanatory note clarifies that women have no right to miscarry themselves. The terms miscarriage and abortion are used interchangeably. Section 312 grants women the right to motherhood and provides ample protection for this right, but it also denies women the right to abortion, implying that she has no control over her own body. It’s not just a question of a woman’s right to her body; it’s also a question of a child’s right to life in a woman’s womb. There is a conflict between the right to life of the unborn child and the right of women over their bodies, i.e. the right to abortion. This issue also raises the question of when life begins—whether it begins immediately after the egg is fertilised, when the foetus acquires a soul, when the foetus can exist independently outside the mother, or when the mother delivers the baby. However, when life begins is a philosophical question, according to Jeffrey M. Drazen (Editor in Chief of the journal The New England Journal of Medicine).

As previously stated, abortion at the beginning of pregnancy is not punishable in the United States, but there is no distinction in India on this basis except in the quantum of punishment: Section 312 prescribes up to three years imprisonment or fine or both for causing the miscarriage of a woman with child and up to seven years imprisonment and fine or both for causing the miscarriage of a woman who is quick with child. The term “woman with child” simply means “pregnant woman.” When a woman conceives and the gestation period or pregnancy begins, she is said to be pregnant. The phrase “quick with a child” refers to a later stage of pregnancy. Quickening is a mother’s perception that the foetus has moved, or that the embryo has moved, or that the embryo has taken on a foetal form. Yet, the right of the unborn child is questioned when the woman’s life is endangered as a result of the pregnancy. The law can be harsh in certain ways, but not completely: for example, section 312 authorises abortion in good faith for the purpose of saving a woman’s life. The Medical Termination of Pregnancy Act expands further the right to abortion.

The Medical Termination of Pregnancy Act’s Statement of Objects and Reasons is as follows: The laws of the Indian Penal Code addressing pregnancy termination, which were adopted over a century ago, were drafted in accordance with British law at the time. Abortion was deemed a crime for which both the woman and the abortionist might be prosecuted, unless the abortion had to be induced in order to preserve the mother’s life. It has been reported that this stringent regulation has been broken in a huge number of instances across the country. Furthermore, the majority of these mothers are married women who have no reason to hide their pregnancy.

In India, even after the legalization of abortion by the Medical Termination of Pregnancy Act, 1971, there are still majority of women who do not have access to safe abortion procedures today. Legal abortion providers are difficult to come by, and women are still resorting to risky techniques and self-induced abortions, making the legalisation of abortion a farce. According to studies, for every legal abortion, there are 2.2 illicit abortions. Furthermore, legalising abortion has been and continues to be a coercive population control tactic. Women who seek abortions at government clinics are forced to ‘accept’ contraception/sterilization after the procedure is completed.

Medical Termination of Pregnancy Act, 1971

On August 25, 1964, the Central Family Planning Board in India suggested that the Ministry of Health form a committee to explore the necessity for abortion laws. The recommendation was approved in the latter half of 1964, with members from various Indian governmental and commercial entities forming a committee. The committee – called Shantilal Shah Committee, after analyzing a vast expanse of statistical data available at that time, issued its report on December 30, 1966 on  the basis of which the government passed the Medical Termination of Pregnancy Act, 1971 (MTP Act of 1971) and liberalized abortion laws in India. It’s worth noting that the MTP Act was first introduced in April of 1972 and then updated in 1975 to minimise time-consuming procedures for location clearance and to make services more accessible. This Act was revised twice, once in 2002 and then again in 2005.The Preamble of the Act states, “An Act to provide for the termination of certain pregnancies by registered medical practitioners and for matters connected therewith or incidental thereto”.[5]

The Act only allows abortion in specific situations. The Act allows for medical abortion up to twenty weeks’ gestation. Though the Act requires the pregnant mother’s written consent before the technique is used on her, the law fails to recognise the social reality that a woman cannot make a free choice. As a result, it is clear that the Act fails to strike a balance between the right of the unborn to be born and the right of the woman who bears, gives birth, and raises the child to choose whether or not to abort the foetus. The influence of the MTP Act should be considered in the perspective of changing social circumstances, values, and attitudes in India, a country with enormous social baggage augmented by societal evils such as illiteracy and poverty. In its most basic form, the MTP Act’s societal ramifications can be divided into two categories: abortion in unmarried girls and abortion in married women. These two have quite distinct meanings. Married women are not regarded a social stigma under the MTP Act, however unmarried females are not easily accepted. The fact that it is unaccepted poses barriers to safe abortions, sometimes negating the objective of abortion, which is to protect the health of the woman who is having an abortion.

With the landmark Medical Termination of Pregnancy Act of 1971, India’s proactive Lawmakers legalised abortion, providing a system aimed to safeguard women from the significant risks of unsafe abortion. Sadly, despite this legal protection, unsafe abortion remains India’s third largest cause of maternal mortality, with over eight women dying every day from causes associated to unsafe abortion. A few previous studies have provided state-level estimates of abortion incidence, but the majority of them have relied on incomplete data sources. Statistics compiled by the government are known to vastly understate abortion incidence, owing to incomplete reporting on facility-based services and the fact that many abortions take place outside of the facility setting. For example, over a 12-month period in 2014–2015, the Ministry of Health and Family Welfare (MoHFW) recorded only 4,877 induced abortions in Bihar—a state with more than 25 million women of reproductive age—while showing 62,466 in the much less populous state of Assam and 51,467 in Uttar Pradesh, the most populous state in India.[6] In 2012, a study using two indirect estimation techniques (the Mishra-Dilip method and the Shah Committee’s method), placed abortion incidence in the six states far higher, ranging from 141,000–151,000 in Assam to 1,140,000–1,180,000 in Uttar Pradesh[7]. However, these methods underestimate abortion because they are based on a small-scale survey and a survey of women. Meanwhile, the 2012–2013 Annual Health Survey estimated that the proportion of pregnancies ending in abortion was about 7% in Assam[8], 5% in Bihar[9], 3% in Madhya Pradesh[10] and 7% in Uttar Pradesh[11], while a 2016 study placed this proportion for South and Central Asia at 25% for the period 2010–2014. Some community-based surveys (such as the National Family Health Survey, or NFHS) collect data on abortion directly from women. However, such studies cannot reliably collect data on incidence because, in response to the stigma associated with terminating a pregnancy, women typically underreport their abortions in face-to-face interviews, a problem that may be exacerbated if women believe abortion to be illegal.[12]

For many years, the ethical debate about the legal stance of preventing unwanted pregnancies has raged around the world, establishing the idea of enacting legislation that would balance the ethical and legal perspectives. Despite legislative and judicial control, ethical controversies surrounding medical abortion of pregnancy persist in India. Though many people believe that medical abortion is immoral, it is now a legal right that women cannot be denied. However, there are some unfavorable consequences of the MTP, which stem from inconsistency in adhering to prescribed standards. The Medical Termination of Pregnancy Act of 1971 significantly expanded the circumstances under which abortion is legal in India. The goal of this Act was for the government to reduce the number of illegal abortions and the associated maternal morbidity and mortality. However, almost 45 years after the groundbreaking legislation, the majority of women seeking abortion still seek abortion services from uncertified providers due to the barriers to legal abortion. While some uncertified providers provide safe services, many perform dangerous abortions which result in complications or fatality. Women with fewer resources, such as low-income rural women and adolescents, are more likely to resort to unsafe abortion and experience complications.

While the prevalence of abortion in India is uncertain, the most widely cited figure suggests that approximately 6.7 million abortions occur each year. Only about one million of these are legal, according to government data. Medical and non-medical practitioners perform the remaining abortions. In India, unsafe abortion rates are extremely high, despite the fact that abortion is legal for a wide range of indications and is available in both the public and private health sectors.

The changing landscape of abortion provisions

A significant piece of legislation that affects roughly half of India has largely gone unnoticed. As part of reproductive rights and gender justice, the Union Cabinet revised the 1971 Medical Termination of Pregnancy (MTP) Act in late January 2020, allowing women to get abortions. The amendment also elevates India to the top of the list of countries that support women who want to make their own decisions based on their own experiences and circumstances. The amendment increased the maximum MTP period for women, including rape survivors, incest victims, differently abled women, and adolescents, from 20 to 24 weeks. MTP is now open to “any woman or her partner,” replacing the previous provision for “only married lady or her husband.” 

The new law is forward-thinking, empathetic, and humanises a highly sensitive issue. India’s move comes at a time when the Supreme Court of the United States (US) is debating the landmark Roe v. Wade case. The 1973 decision safeguards a pregnant woman’s right to choose whether or not to have an abortion without undue government interference. It was a landmark piece of legislation that served as a source of inspiration for women all around the world. Roe v. Wade is being shaken to its foundations by a conservative US Supreme Court decision that requires doctors who perform abortions to have admitting privileges at a nearby hospital.

In the instance of foetal anomalies, the Indian amendment states that there is no limit on gestational age. This is about maternal mortality and morbidity as a result of unsafe abortions. Women will also be spared the worry and anguish of having to seek permission from the courts as their time runs out. The change defines the position of practitioners who are hesitant to intervene in rape and incest situations. The amendment, according to critics, does not go far enough. The lack of scalability in the supplier base is their main issue. The amendment is sufficiently large to allow for revisions as the dialogue establishes its parameters. In the field of public health, framing is crucial. What is at stake, who is responsible, and where answers might be found are all determined by frames. Gender justice, reproductive health, maternal health and a woman’s right to her body are issues that need special attention because what is at stake is not just the welfare of women but also that of entire societies.

The realities of public health in India vary greatly from state to state. According to The Lancet’s first large-scale study on abortions and unwanted pregnancies conducted in 2017, one in every three of India’s 48.1 million pregnancies ends in an abortion, with 15.6 million occurring in 2015. Abortion laws are fundamentally based on determining when life begins, and societies will always disagree on this. When does the foetus’ life become valuable enough to warrant protection? After how many months does it make sense to limit a woman’s right to MTP? There is no single answer, and proponents of anti-abortion legislation who believe that life begins at fertilisation have just as strong an argument as those who do not. That is why we require laws. They do not always reflect a society’s values, but in the face of uncertainty, laws must provide a framework within which people can navigate understanding what is legal and what is not. This emphasizes the point that the limit may appear arbitrary, but it is necessary. This isn’t a reflection of what’s right or wrong. In the case of abortion, legislators have established a time limit. Some countries have a 12-week waiting period, while others, such as India, now have a 24-week waiting period.

Millions of women worldwide rely on a variety of abortion options, ranging from expensive private clinics to quacks. Unwritten and unsaid prejudices follow them from menstruation to pregnancies to menopause, in the majority of cases with no legal or family support. One set of uncertainties has been removed as a result of the amendment. A reversal is not possible, and this is a significant step forward for women.

Conclusion

We claim that women’s control over their own childbearing is an essential component of reproductive rights, and that all effective and safe means of ensuring this control must be prioritised in policy and programming. The legal right to abortion is undoubtedly a critical component in ensuring that women have control over their childbearing destinies. However, many women around the world do not have access to not only safe abortions, but also to safe and effective contraception. For these women, abortion is frequently a choice based on a lack of alternative options: the extent to which they resort to risky or safe abortions is essentially determined by the realistic options available to them for preventing unwanted pregnancies in the first place. If reproductive rights for women in developing countries are to be realised, it is critical to address women’s basic need for access to adequate contraceptive options as well as the need for safe abortion. The fact that the relationship between abortion and contraception for women in developing countries is poorly understood is a major reason why it has not been adequately addressed. Although large-scale surveys such as the Demographic and Health Surveys (DHS) have provided valuable data on contraceptive use rates and trends in a number of countries, they provide only limited information on factors underlying women’s reproductive behaviour, such as motivations for childbearing, decision-making processes about contraception or abortion, or barriers to accessing services. So far, the majority of knowledge about reproductive choices and behavior from the perspective of women has come from small-scale, community-based, qualitative studies; however, these are difficult to generalize. Higher-quality, large-scale survey data on these issues are critical not only for better estimating the number of women who practice abortion, but also for fully understanding the context in which women make contraceptive decisions, experience unwanted pregnancies, and resort to abortion.

Women in India have a variety of pregnancy-related health care needs, which vary depending on the outcome of their pregnancy: Women carrying a pregnancy to term, as well as some women who have late miscarriages, require prenatal and delivery care; women who have complications from unsafe abortions require post abortion care; and women and their infants may require emergency maternal and newborn health services. Safe and legal abortion services are only one component of a comprehensive package of maternal health care, and strengthening and expanding abortion-related services is a critical step toward improving overall provision.

In India, the MTP Act, which legalised abortion in 1971, did not produce the desired results. Despite the existence of moderate policies, the majority of women continue to use unsafe abortion methods. This adds significantly to the burden of maternal morbidity and mortality. While laws are not in competition between countries, they are indicators of where rights, especially women’s rights stand. Currently, 26 countries in the world do not permit abortions and 39 allow it only when the mother’s life is at risk.

With the revision of the 1971 Medical Termination of Pregnancy (MTP) Act in late January 2020, allowing women to get abortions and increased the maximum MTP period for women, including rape survivors, incest victims, differently abled women, and adolescents, from 20 to 24 weeks. MTP is now open to “any woman or her partner,” replacing the previous provision for “only married lady or her husband.” Furthermore, with the Confidentiality clause, the name and other particulars of a woman whose pregnancy has been terminated cannot be revealed except to a person authorised by law. Extended MTP services under the failure of contraceptive clause to unmarried women to provide access to safe abortion based on a woman’s choice, irrespective of marital status.

It is imperative now that the recent changes, rules, and regulations are adequately communicated and widely disseminated to not just service providers but also other stakeholders, such as programme managers, NGOs and the community. In collaboration with WHO India, the MoHFW through the SAMARTH initiative (Sustain-Accelerate-Mainstream Access to Reproductive-health Through Health-system) is supporting the dissemination of this evidence-based information to accelerate achievement of ‘universal reproductive health’ in India.[13]


[1] Betty Friedan, Abortion: A Woman’s Civil Right, 39 (reprinted in Linda Greenhouse and Reva B. Siegel, 1st edn 1999).

[2] 410 U.S. 113 (1973).

[3] 505 U.S. 833 (1992).

[4] Section 312, Indian Penal Code.

[5] Medical Termination of Pregnancy Act, 1972 (Act of 1971), Preamble.

[6] Ministry of Health and Family Welfare (MoHFW), Health and Family Welfare Statistics of India 2015, New Delhi: MoHFW, Statistics Division, 2015.

[7] Banerjee S, Indirect estimation of induced abortion in India, working paper, New Delhi: Ipas Development Foundation, 2012.

[8] Office of the Registrar General and Census Commissioner, India, Annual Health Survey 2012–13 Fact Sheet: Assam, no date,

[9] Office of the Registrar and Census Commissioner, Annual Health Survey 2012–13 Fact Sheet: Bihar, no date, http://www.censusindia.gov.in/vital_statistics/AHSBulletins/AHS_Factshee….

[10] Office of the Registrar and Census Commissioner, Annual Health Survey 2012–13 Fact Sheet: Madhya Pradesh, no date, http://www.censusindia.gov.in/vital_statistics/AHSBulletins/AHS_Factshee….

[11] Office of the Registrar General and Census Commissioner, India, Annual Health Survey 2012–13 Fact Sheet: Uttar Pradesh, no date, http://www.censusindia.gov.in/vital_statistics/AHSBulletins/AHS_Factshee….

[12] Stillman M et al., Abortion in India: A Literature Review, New York: Guttmacher Institute, 2014, www.guttmacher.org/report/abortion-india-literature-review.

[13] India’s Amended Law Makes Abortion Safer And More Accessible. (2021, April 13). https://www.who.int/india/news/detail/13-04-2021-india-s-amended-law-makes-abortion-safer-and-more-accessible.

Author: Anindita Sarma Pujari, National Law University and Judicial Academy, Assam

Editor: Kanishka VaishSenior Editor, LexLife India

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