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

1

Acknowledgment

I take this opportunity with great pleasure to thank faculty In-

charge 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.

2

Index

Introduction 4

India in Reality 4

Present Deliberation 7

A Complex Issue: Pro-life vs. Pro-choice 8

Laws of Abortion in Other Countries 12

A Balanced Approach 12

Abortion in Comparison to Euthanasia 13

Conclusion 14

Bibliography 16

3

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

India’s “Balanced Approach”, lastly my take on the issue of

abortion in India.

India in Reality

India’s 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

4

related complications. 1 Most abortion-related maternal deaths are

attributable to illegal abortions.2 In the following table Number of

abortions reported includes legal reported induced abortions.3

Year197

21975 1980 1985 1990 1995 2000

Number of

abortions

reported

243

00

2141

97

3884

05

5837

04

5812

15

5709

14

7231

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 1970’s 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.

1 "Introduction". Consortium on National Consensus for Medical Abortion in India. http://www.aiims.edu/aiims/events/Gynaewebsite/ma_finalsite/introduction.html.

2 "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

5

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 women’s

life which is buried in silence. In a country like India, women’s

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

women’s 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

6

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

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.

7

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

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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 mother’s 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 mother’s 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.

9

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 stages-

1. 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 women’s 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 :

“Women’s 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 that-

“No 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.

4 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 19936 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, it’s 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 women’s right to choose exist but

beyond that gradually the unborn child right starts taking place

and the women’s 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 twenty weeks, the opinion of two registered medical

8 410 U.S. 113

11

practitioners is required and when the limit of twenty weeks is

crossed then procedure is performed only to save the woman’s 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 mother’s life is at stake.

4. The stage of 20 th week of gestation and above- Her right to

choice ceases to exist the moment 20th 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 mother’s 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 fetus’s 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

9AIR 1962 Mad 14610 P J Fitzgerald, Salmond on Jurisprudence, Ed. 12th, Universal Law Publishers, 200411AIR 1962 Mad 14612 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 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 1882.14 842 Sw 2d 58815 1935 SC (HL)57: (1935) AC 209.

13

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

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 women’s rights advocates insist it

forms part of a woman’s 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 woman’s 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

17 410 U.S. 113, 93 S. Ct. 705, 35 L. Ed. 2d 147 (1973).18 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

India’s 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 24-

week limit. In France and Germany, appeal has been made to make

it within 12 weeks.

17

When developed countries like U.K, France, Germany, etc are

campaigning for lowering the abortion limit then why should India

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 woman’s 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

18

her own child, how can we tell other people not to kill one

another?”

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.

Webliography

http://www.aiims.edu/aiims/events/

Gynaewebsite/ma_finalsite/report/1_3_8.html

http://74.125.95.132/search?

q=cache:nNTvD6Ao_R8J:www.cehat.org/aap1/

policyreview.pdf+abortion+amendment+in+india

&cd=2&hl=en&ct=clnk&gl=in

http://in.keegy.com/tag/time-limits/

http://74.125.95.132/search?

q=cache:vKspT7jCLXYJ:www.searo.who.int/

19

LinkFiles/

Regional_Health_Forum_Induced_Abortion.pdf+a

bortion+amendment+in+india&cd=9&hl=en&ct

=clnk&gl=in

http://newsblaze.com/story/

20081027115531zzzz.nb/topstory.html

http://linkinghub.elsevier.com/retrieve/pii/

S0968808004240174

http://policywise.net/2007/09/20/why-sex-

determination-should-be-legal-in-india/

http://infochangeindia.org/200804307089/

Children/News-Scan/PM-denounces-abortion-of-

females.html

http://www.highbeam.com/doc/1P3-

1427436101.html

http://www.zeenews.com/news460332.html

http://www.india-server.com/news/abortion-limit-

may-be-raised-to-24-3819.html

http://www.indiatoday.com/itoday/20030512/

health.shtml

http://www.dnaindia.com/report.asp?

newsid=1230474

http://www.1to9months.com/abortion.html

www.aiims.edu/aiims/events/Gynaewebsite/

ma_finalsite/index.html

www.aiims.edu/aiims/events/Gynaewebsite/

ma_finalsite/report/1_1_1.htm

blogs.expressindia.com/showblogdetails.php?

contentid=394265

www.cehat.org/aap1/work1.pdf

www. india together.org/manushi/issue126/

abortion .htm

20

www.flipkart.com/environmental-justice- rights -

unborn -future/1844073661-6zx3fnjlpc

www.indg.in/primary-education/education-as-

fundamental-human-right/ child - rights -handbook

www.amicus.iup india .org/RighttoLife_ovw.asp

pib.nic.in/feature/fe1299/f3012991.html

www. india together.org/2008/aug/ksh-

mtpchoice.htm

http://www.aiims.ac.in/aiims/events/Gynaewebsite/ma_finalsite/

report/1_1_1.htm.

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