Right To Abortion in India: A Legal Perspective in Favour Of Women

Abstract

As we perceive India is vast country with huge population. There are various issues in India but in this research paper we deliberation abortion right of women in India. Right of abortion in India is a decisive approach of women’s reproductive rights and gender equality. Irrespective of various years of liberal legislation most women in India still lack use to safe abortion care. In India legally abortion governed by Medical Termination of Pregnancy (MTP) Act, 1971 which allows for abortion under specific conditions such as risk to the women’s life, fetal abnormalities and cases of rape or insect.

Before the enactment of this Act, abortion was illegal in India and was offence under the Indian Penal Code, 1860 except when done in good faith to save the life of a pregnant women. This paper also features the judicial interpretation that have progressively expanded women’s reproductive rights. It also finds the legal foundation of abortion rights in India highlighting the constitutional provides under Article 21 (Right to Life and Personal Liberty) and Article 14 (Right to Equality) which advocacy women’s autonomy over her reproductive choices. This paper summarizes by advocating for further reforms to guarantee equitable access to safe and legal abortion services for all women.

Introduction

The term abortion is also known as “induced abortion” refers to the medical procedure to end a pregnancy. The practice of abortion and the laws related to it have always been a topic of debate on different customs, traditions, moral beliefs, etc. While some people consider the termination of pregnancy an intrinsic right in women’s life, others view it as the killing of the fetus. In layperson’s language, the term abortion connotes the procedure for termination of pregnancy resulting in the death of the embryo or fetus.

In case Jacob George v. State of Kerala (1994) the apex court dealing with these two terms, abortion and miscarriage held that “miscarriage” connotes “spontaneous abortion” whereas “abortion” is said to be ‘miscarriage produced by unlawful means.[1] The court further opined that the destruction of the life of fetus is abortion or miscarriage.

The Legal Framework of Abortion in India

As we know the termination of pregnancy was illegal in India before 1970s, it was only after enactment of the MTP Act, 1971, that the medical termination of pregnancy was allowed under certain circumstances expressly mentioned in the Act. The earliest legislation that contains provisions for abortion is Indian Penal Code, 1860.

Indian Penal Code, 1860

There are some provisions related abortion in Indian Penal Code, 1860.

Section 312 of the Indian Penal Code, 1860

This section criminalizes causing a miscarriage (abortion). The section comes with the exception that a person causing miscarriage will not be held guilty if the act is done to save the life of a women who is pregnant. The above provisions deal with two kinds of miscarriage, first when miscarriage is caused by a women bearing a child and when women is quick with the child. The second situation is when the movement of the fetus can be felt (mostly after 15–16 weeks of conception).

• In the case of first type of miscarriage the accused will be punished for term which may extend up to three years with fine.
• In the second situation the imprisonment will be for a tenure which may up to seven years with a fine.[2]

The provision also inculcates the women herself, who is pledged if she is the one who caused miscarriage.

Section 313 of the Indian Penal Code, 1860

This section deals with causing miscarriage without woman’s consent. In this section it is immaterial whether the pregnant woman was quick with child or not the punishment will be for period of ten years, which may extend to imprisonment for life with a fine.

Section 314 of the Indian Penal Code, 1860

This section deals with death caused by act done with the intent to cause miscarriage. Whoever with mens rea to cause the miscarriage of a woman with child does any act which causes the death of woman shall be liable for punishment which may extend up to ten years along with fine.[3]

The provision also provides that if the act is done without the consent of the woman, then the person behind the act shall be punished with imprisonment for either up to ten years or imprisonment for life. It also states that the knowledge of the offender that his or her action may cause the death of the pregnant woman is not an essential ingredient to prove him guilty under this provision.

Section 315 of the Indian Penal Code, 1860

This section deals with act done with intent to prevent child being born alive or to cause it to die after birth.[4] Such act is punishable with imprisonment, which can extend up to ten years with or without fault. The provisions make an exception for the act in good faith to save the life of the pregnant woman.

Section 316 of the Indian Penal Code, 1860

This section basically deals with the causing death of quick unborn child by act amounting to culpable homicide. Whoever does any act under such circumstances to cause the death of the quick child and thereby causes the death of the child will be held liable under this offence. The provision provides for imprisonment, which may extend up to ten years with fine.

Constitutional Provisions

There is no provision under Indian Constitution expressly talks about abortion or miscarriage. The country’s court have time and again held that the right to abortion is safeguarded under the Constitution of India. Article Twenty-One of Constitution states that no person shall be deprived of his right to life and personal liberty. Held in case Suchita Shrivastava and Another v. Chandigarh Administration.

In pursuant to Article Fourteen of the Indian Constitution the code held that forcible sterilization or abortion if a mentally retarded person is a violation of the right to equality.

Preconception and Prenatal Diagnostic Technique Act, 1994

The paramount objective of the enactment of the Act was to restrict prenatal diagnostic techniques to control the rising issue related to such prenatal diagnostic techniques to control the rising issue related to such prenatal diagnostic.

Medical Termination of Pregnancy Act, 1971

The Act came into force in 1973. A medical termination bill was placed before Lok Sabha and Rajya Sabha based on the suggestion of the Shantilal Committee. This bill was passed in Parliament in August 1971 and received presidential assent on 10 August 1971. The Act was paramount enacted to reduce unsafe abortion and establish a proper procedure for the regulation of abortion across the country. The Act was initially not applicable to the Jammu and Kashmir. However, after the repealing of Article 370 of Indian Constitution it now applies to whole of India.

It was enacted to provide a separate law for the termination of pregnancies under certain specific condition by registered medical practitioners and all other matter related to it. It also aimed to prevent abortion from untrained person. This Act consists of eight sections, which deals with various aspect such as place, time and circumstances, in which termination may be done by registered medical practitioners.

Protection and Conditions for Termination

The Medical Termination of Pregnancy Act confers full protection to a registered medical practitioner against for any damage caused to a woman seeking abortion, which is done in good faith.

• It allows pregnancy to be terminated if the tenure of pregnancy does not exceed 12 weeks on the approval of registered medical practitioner.
• If the tenure of pregnancy exceeds 12 weeks but does not exceed 20 weeks, termination is allowed on the approval of two registered medical practitioners.

Grounds for Termination

• Risk to the life of the pregnant woman.
• Grave injury to the physical or mental health of pregnant women.
• Substantial risk that if the child is born, it would suffer from physical or mental abnormality.
• Pregnancy because of failure of contraception to a married woman.
• Pregnancy occurring from any sex crime, such as rape.

It was also stated that no termination of pregnancy shall be done at any place other than government hospital or place approved by government.

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Medical Termination of Pregnancy Amendment Act, 2002

This Act replaced the word lunatic with mentally ill person in clauses (a) and (b) of Section 2 of the Act. The word “mentally ill person” was also substituted in Section 3(4)(a) of the Act.

The amendment of 2002 also inserted a new provision Section 4 which lays down the places where in termination of pregnancy for the purpose of this Act, may be carried out.

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Medical Termination of Pregnancy Rules, 2003

The Rule was published to further ensure the effective implementation of the Act and to cope with some lacunas that could not be filled in the previous amendment.

District Level Committee

The Rules provided for the composition and tenure of district level committee (Rule 3). As per it the committee shall include gynecologist/surgeon and other member for the local medical profession, NGO, and Panchayati Raj institution. It also mandates the presence of women on the committee.

Training and Experience

It also provides the rules for the provision of experience, training and practice for medical practitioner under Section 2(d).

Termination Beyond 24 Weeks

Rule 3B mention the categories of women that permitted to terminate their pregnancies exceeding 24 weeks.

Permitted Categories of Women
Sexual assault or rape or incest survivor
Minor
Physically disabled women
Substantial risk to the fetus
Mentally retarded women: a child who may have the risk of physical or mental abnormalities if the pregnancy is allowed.
A woman who is pregnant in a period of disasters, emergencies, or humanitarian setting as declared by the government for the time being.

Inspection and Approval of Places

It further provided for a mandatory inquiry investigation in the places where such operations were carried out. This inquiry or investigation was to be conducted by Chief Medical Officer according to Rule 4.

• Approval of place (Rule 5)
• Suspension of approval certificate of the place (Rule 7)
• Provision of review by the owner of the suspension or cancellation order by the government (Rule 8)

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Medical Termination of Pregnancy Amendment Bill, 2020

The medical termination bill was presented by Dr Harshvardhan Goyal, the Union Minister for Health and Family Welfare in the Lok Sabha on March 2, 2020. The bill received presidential assent on March 25, 2021, and thus the Medical Termination of Pregnancy Amendment Act of 2021 was enacted.

This bill making it easier for women to terminate the pregnancy safely and legally. It increases the permissible gestation to 24 weeks provided it required the approval of two medical practitioners. This is done keeping in mind the rape survivor, victim of incest and other vulnerable women such as minor, differently abled etc.

The amendment also allowed all women, not just married ones, to seek abortion in the case of contraceptive failure. In addition, the upper gestation limit would not be applied in case of significant fetal abnormalities diagnosed by medical board.

This directs the maternal mortality and morbidity arising from unreliable abortion. Women will also be spared from the agony of seeking permission from the court as there are various cases where concerned women do not realise in the first five months that they are pregnant and times run out on them.

The bill also emphasised on maintaining the confidentiality of all women undergoing termination of pregnancy. This is a great move for a country like India where abortion is still associated with social stigma and justice for women. India will now stand as one of the nations with an extraordinarily progressive law which allow legal abortion on a broad range of therapeutic, humanitarian and social premises.

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Drawbacks of the New Abortion Law in India

The medical boards were primarily established to check whether the precondition established under the Act were satisfied or not. However, several recent incidents show that these boards are often seen interfering in issues of viability of the fetus, the possibility of corrective surgery, judging on social stigmas and taboos, moral policing, etc.

Thus, in certain cases these boards have proven to be hindrance to women wanting to terminate their pregnancies. The Act further equip the right to abortion only to certain women falling into the categories mentioned under the Act, thus discriminating contra other women who do not fall under this category.

It fails to have a right based approach but has restrictive approach. The right to abortion is an inherent right of women and thus, this Act infringed the same and fails to provide complete autonomy to the women who choose to terminate their pregnancy.

Judicial Interpretation

Nand Kishore Sharma and Others v. Union of India (2005)

The court while dismissing the petition, held the section under challenges to be valid. It emphasized the object of the MTP Act and opined that this law was enacted to make provisions relating to abortion as stringent and effective as possible. In no way were these provisions enacted to allow the termination of pregnancy.[8]

Suchita Srivastava v. Chandigarh Administration (2009)

In Suchita Srivastava v. Chandigarh Administration, a woman with intellectual disabilities was impregnated following a sexual assault. The Chandigarh Administration sought permission from the court to terminate the pregnancy. The Supreme Court held that a woman’s right to make reproductive choices is a dimension of personal liberty under Article 21. It emphasised that reproductive choices include the right to continue or terminate a pregnancy and that a woman’s right to privacy and bodily autonomy should be respected.[9]

Devika Biswas v. Union of India (2016)

The apex court while adjudicating and considering all the facts, held that such a practice of sterilization is violative of Article 21, thereby stating that a person has a right to reproductive choice and that it falls within the ambit of Article 21.[10]

Meera Santosh Pal v. Union of India (2017)

Meera Santosh Pal v. Union of India case involved a woman who sought to terminate her 24-week pregnancy due to severe fetal abnormalities. The Supreme Court granted permission for abortion, stating that the woman’s right to life included the right to make reproductive choices. The ruling underscored the significance of bodily autonomy and health risks associated with continuing a pregnancy under such circumstances.[11]

XYZ v. State of Maharashtra (2021)

In XYZ v. State of Maharashtra, the Supreme Court allowed a minor to terminate her pregnancy beyond the 20-week limit due to her socio-economic condition and the impact of the pregnancy on her mental health. The ruling highlighted the importance of considering individual circumstances and mental health when adjudicating abortion cases.[12]

Deepika Singh v. Central Administrative Tribunal (2022)

The Supreme Court in Deepika Singh v. Central Administrative Tribunal expanded the definition of a family to recognize relationships outside the traditional marriage institution. The judgment paved the way for the interpretation of reproductive rights for unmarried women, affirming that the law should reflect the realities of modern relationships and not be limited by outdated societal norms.[13]

X v. Principal Secretary, Health, and Family Welfare Department (2022)

This landmark decision in X v. Principal Secretary, Health and Family Welfare Department removed the artificial distinction between married and unmarried women in the Medical Termination of Pregnancy Act. The Supreme Court ruled that all women, regardless of marital status, have the right to seek an abortion within the legally permitted gestational period. The court emphasised that the Medical Termination of Pregnancy Act should not discriminate based on marital status and that the right to reproductive autonomy, privacy, and dignity under Article 21 applies equally to all women.[14]

Minor R Mother H v. State of Nct of Delhi and Another (2023)

The Delhi High Court allowed the miner’s plea for termination of pregnancy. It also issued certain guidelines that are to be followed in rape and sexual assault cases where the victim’s pregnancy exceeds 24 weeks. The following guidelines were issued by the court:

• Mandatory urine pregnancy test of victim of sexual assault or rape at the time of medical examination.
• In case of major victim if found pregnant due to sexual assault or rape expresses her will to abort the pregnancy she has to be produced before the medical board on the same day by the investigating officer.
• The court further directed the government to ensure that the provision of Medical Termination Pregnancy Act is implemented effectively, and that medical board must be constituted in all government hospitals to ensure the proper functioning of medical termination pregnancy centers.
• In the case of minor victim who is pregnant must be produced before the medical board upon the consent given by her legal guardian for the same and for the abortion as well.[15]

ABC v. State of Maharashtra (2023)

The Bombay High Court allowed the request of the petitioner to undergo an abortion while she was 33 weeks pregnant. It also quashed the recommendations of the medical board, wherein the board advised not to terminate her pregnancy because of the period of the pregnancy.[16]

Challenges in Accessing Abortion Services

Legal And Policy Barriers

• Restrictive Laws: Abortion is limited or banned in many countries and regions, except for specific circumstances like rape or incest, due to restrictive laws.
• Gestational Limits: Few places impose restriction on how late an abortion can be performed as early as 12-20 weeks of pregnancy. These restrictions can prevent individuals from seeking abortion services when they may not have had access or resources to do so earlier.
• Criminalization: In certain places even attempting an abortion or seek services outside of law can result in legal prosecution, criminal penalties, or imprisonment.
• Changes in Law: Shifts in political leadership or public opinion can lead to sudden changes in abortion policy, creating uncertainty about access and discouraging individuals from seeking care.

Financial Barriers

• Cost of Services: Abortion services can be pricey, especially when not wrapped by insurance. In few countries, even in areas with legal abortion access, the cost may be prohibitive for individuals who lack adequate health insurance or financial resources.
• Insurance Limitations: In few countries, including the United States, private insurance and public health programs (like Medicaid) may not cover abortion services, or they may impose restriction on coverage.
• Travel and Accommodation: For people living in arena where abortion is unavailable or restricted, accessing services may require significant travel, overnight stays, and additional costs for transportation and accommodation, including to the financial burden.

Geographical Barriers

• Distance from Providers: In rural or remote areas, clinics that provide abortion services may be exceedingly rare, requiring long travel distances to reach a facility. This is peculiar problematic for people without reliable transportation or access to financial resources for travel.
• Availability of Providers: Even in urban areas, the number of healthcare providers offering abortion services may be restricted due to the political, social, or professional stigma surrounding the procedure. Many providers are deterred from offering abortion services due to legal risks, financial difficulties, or ethical objections.

Social And Cultural Barriers

• Stigma and Shame: Abortion is often surrounded by social stigma, which can deter individuals from seeking care. This stigma can led to feelings of shame, guilt, or fear of judgment from family, friends, religious groups, or society at large.
• Religious Beliefs: In some communities, deeply ingrained religious beliefs oppose abortion, making it more difficult for individuals to access services without facing significant social or familial pressure. This can create a situation where individuals may feel isolated or unsupported in their decision.
• Lack of Support Networks: Some individuals may lack access to supportive partners, friends, or family members who can help them navigate the process of obtaining an abortion, which can exacerbate feelings of isolation and complicate access.

Psychological And Emotional Barriers

• Fear of Judgment: The pressure of potential judgment from medical professionals or society can cause individuals to delay or avoid seeking an abortion, even if it is legally or medically necessary.
• Mental Health Considerations: Some individuals may experience anxiety or distress regarding their decision to seek an abortion. This may be compounded by pressure from family members, partners, or the broader community.

Misinformation

• Lack of Accurate Information: In many places, individuals may not have access to accurate information about abortion services, their rights, or the risks involved. This misinformation can be perpetuated by anti-abortion campaigns, religious groups, or even certain media outlets.
• Anti-Abortion Counselling: In certain regions, individuals may be subjected to biased counselling intended to dissuade them from pursuing abortion, which can lead to confusion and delay.

Healthcare Provider Barriers

• Lack of Training: In some areas, especially in low-resource settings or developing countries, healthcare professionals may lack the training or equipment necessary to safely perform abortions, particularly in the first trimester.
• Medical Misinformation: In some cases, individuals seeking abortion care may be misinformed by healthcare providers or other sources, leading to confusion about the procedure, its safety, or the availability of services.

Public Health Implications

Physical Health Consequences

• Raised risk of unsafe abortions: 45% of abortions worldwide are unsafe, leading to twenty-two million unsecured abortions annually.
• Higher rates of in respect of abortion complications: Infection, bleeding, and organ damage.
• Raised risk of maternal mortality: 47,000 women die annually from unsecured abortions.
• Long-term health consequences: Infertility, chronic pain, and mental health issues.

Mental Health Consequences

• Anxiety and depression: Women denied abortions experience raised anxiety and depression.
• Post-Traumatic Stress Disorder (PTSD): Traumatic experiences in respect of abortion.
• Stigma and shame: Societal attitudes give to mental health distress.
• Suicidal thoughts and behaviours: Increased risk among women denied abortions.

Social and Economic Consequences

• Unintended pregnancies and births: Increased risk of poverty, educational disruption, and reduced career opportunities.
• Raised poverty and economic instability: Raising unintended children can perpetuate poverty.
• Reduced educational and career opportunities: Women may drop out of school or abandon career goals.

International Comparison

Adoption has been prevalent in India for several years. Because in India Hinduism is widely practiced in religion and history contained chronical of saints and royals who were and were not adopted. In context of conventional adoption which started in regard of personal and family concerned and developed into a movement for child welfare reform. In Madras and Bombay presidency, child act was passed in 1920 which regarded state with the obligation of caring for impoverished and neglected children.

The purpose of this particular act is to grant security and care for children. Laxmi Kant Pandey v. Union of India 1984 the court states that every child as right to love and be loved. However, if the natural parents or any other person is not able to take of the child or kid has been abounded by his or her family then adoption is the greatest option. In 1986 Central Adoption Resource Agency was incorporated in India for better condition of inter country adoption procedure. The main work of Central Adoption Resource Agency is to see and managed the process of adoption.

Abortion Rates Have Reduced in Countries Where It Is Legal

Estimated abortion rate per 1,000 women aged from 15 years to 49 years.

The global scenario in abortion law has been inclined liberalization. In the past thirty years, more than sixty countries have modified their abortion laws. Here’s a look at how abortion laws modified in countries around the globe.

United States

The supreme court decision on June 24, 2022, to struck down Roe v. Wade overturns almost fifty years of judicial principal that conferred a constitutional right to go for an abortion. In 1973 the court held that the constitution provides the right to choose to have an abortion, though it permitted regulation after the first trimester of pregnancy. After this United States becomes one of the first countries to liberalize its abortion laws, along with several Western European nation. For decades, states have started and enacted various laws regulating abortion. Some passed laws to protect abortion access, while others bind more onerous regulation on abortion providers and sought to prohibit abortion at earlier points in pregnancy. Various states have passed increasingly strict abortion laws in recent years, sometimes banning the procedure after as few as six weeks of pregnancy.

China

China liberalized its abortion law in the 1950s and advertises the procedure under its one child policy, which was implemented in 1979 to restrict the population extension by restricting families to one child. The policy, under which abortion services were made widely present, came with severe coercive measures including fines, compulsory sterilization and abortion to deter unauthorized births. China promoted this long-standing limit to a two-child policy in 2016 along with other incentives to abet population growth aimed a quickly aging population. In 2021, it increased the restriction to three children and China’s State Council issued guidelines on women’s development that called to reduce “non- medically necessary abortion”.

France

In 2024, France became the first country to consecrate abortion rights in its constitution. Abortion rights had been decriminalized in 1975 in tendentious act that legalized the procedure up to the tenth week of pregnancy. The gestational restrict was applicable to twelve weeks in 2001 and fourteen weeks in 2022. That same year, following to overturn Roe v. Wade, the country sought to formally protected the law with constitutional amendment.

Ireland

In 2018, the Irish parliament legalized the termination of pregnancy before twelve weeks, as well as in cases in which the health of the mother is at stake. Previously, Ireland had one of the most restrictive abortion laws in Europe, codified in a 1983 constitutional amendment that productively banned the practice. The 2012 death of Savita Halappanavar after she was denied an emergency abortion reignited public debate and protest and prompted a countrywide referendum to overturn the amendment; the referendum passed with 66 percent of the vote. In 2019, abortion was legalized in Northern Ireland, which is part of the United Kingdom (UK).

Poland

In 2020, Poland’s Constitutional Tribunal ruled that abortions in cases of fetal impairment are unconstitutional, making the country’s abortion law one of the strictest in Europe. Because various abortions function in Poland prior to the ruling were due to fetal abnormalities, the decision-initiated a near-total ban. In response, hundreds of thousands of people took to the streets to protest the decision, though it remains in effect. Polish law still allows abortions in cases of rape, incest, and life-threatening pregnancies, though doctors have reportedly been reluctant to perform legal abortions since the ruling.

Suggestion

Legislative Reforms

• Rectify the Hindu Adoption and Maintenance Act, 1956 to include provisions for single parents, LGBTQ+ individuals, and couples with disabilities.
• Strengthen the Juvenile Justice (Care and Protection of Children) Act, 2015 to ensure child-centric adoption processes.
• Implement a uniform adoption law applicable to all citizens, regardless of religion or caste.

Procedural Simplification

• Streamline adoption procedures to reduce waiting periods.
• Initiate online platforms for adoption applications and tracking.
• Form centralized adoption authorities to coordinate inter-state adoptions.

Support Systems

• Plan counselling services for adoptive parents and children.
• Create support groups for adoptive families and birth parents.
• Provide financial assistance and subsidies for adoptive families.

Awareness And Education

• Launch public awareness campaigns to promote adoption.
• Integrate adoption education in school curricula.
• Oversee workshops for judges, lawyers, and social workers.

Child-Centric Approach

• Paramount child welfare and best interests in adoption decisions.
• Ensure child participation in adoption processes.
• Strengthen post-adoption monitoring and support.

Conclusion

In conclusion, the right to abortion in India has undergone significant transformations, reflecting the country’s commitment to women’s reproductive autonomy and rights. The Medical Termination of Pregnancy (Amendment) Act, 2021, marks a crucial milestone, expanding access to safe and legal abortion while balancing individual freedom with fetal interests.

Aligning with international human rights standards, India’s progressive legislation and judicial interventions, such as the landmark Suchita Srivastava vs. Chandigarh Administration case, have reinforced women’s agency over their bodies. However, challenges persist, including social and cultural barriers, inadequate healthcare infrastructure, and restrictive norms. To ensure reproductive justice, it is imperative to enhance awareness, education, and access to affordable services, ultimately promoting gender equality and empowering women to make informed choices about their reproductive health.

References

1. Jacob George v. State of Kerala, (1994).
2. Indian Penal Code, 1860, Section 312, Act of Parliament, 1860.
3. Indian Penal Code, 1860, Section 314, Act of Parliament, 1860.
4. Indian Penal Code, 1860, Section 315, Act of Parliament, 1860.
5. Diksha Pallial, Abortion Laws in India, https://blog.ipleaders.in/abortion-law-in-india/ (last visited September 15, 2024).
6. Seep Gupta, Medical Termination of Pregnancy Act, 1971 along with Bill, 2020: A Critical Analysis, https://blog.ipleaders.in/medical-termination-pregnancy-act-1971-along-amendment-bill-2020-critical-analysis/#Medical_Termination_of_Pregnancy_Act_1971 (last visited September 15, 2024).
7. Diksha Pallial, Abortion Laws in India, https://blog.ipleaders.in/abortion-law-in-india/ (last visited September 15, 2024).
8. Nand Kishore Sharma and Others v. Union of India, (2005) 5 SCC 634.
9. Suchita Srivastava v. Chandigarh Administration, (2009) 9 SCC 1.
10. Devika Biswas v. Union of India, (2016) 10 SCC 726.
11. Meera Santosh Pal v. Union of India, (2017) 3 SCC 462.
12. XYZ v. State of Maharashtra, (2021).
13. Deepika Singh v. Central Administrative Tribunal, (2022) 3 SCC 199.
14. X v. Principal Secretary, Health and Family Welfare Department, (2022).
15. Minor R Mother H v. State of NCT of Delhi and Another, (2023).
16. ABC v. State of Maharashtra, (2023).
17. Abortion Law: Global Comparisons, https://www.cfr.org/article/abortion-law-global-comparisons (last visited September 25, 2024).