Since 2011, 28th September has been globally recognised as ‘International Safe Abortion Day’. To mark this, we look at some of the contrasting abortion policies of countries throughout the world.
Great Britain & Northern Ireland
Abortion law in Great Britain is based on the 1967 Abortion Act. This permits abortion when the pregnancy has not exceeded 24 weeks, and has no age limit, although counselling is recommended if a very young woman requests an abortion. There is no time limit to an abortion, however, if there’s a substantial risk to the woman’s life or of ‘foetal abnormalities’. The law does require that a reason for the abortion has to be asked, and two doctors must ensure the Abortion Act’s requirements have been fulfilled and sign the relevant certificate. Although the law appears to require medical grounds for an abortion, doctors can sanction an abortion without genuine medical grounds, meaning Great Britain has few restrictions on abortions.
In Northern Ireland, abortions are illegal except where the woman’s life is at risk or there’s a permanent or serious risk to her mental or physical health. This summer the UK government changed policy, granting Northern Ireland women access to NHS-funded abortion services in England for the first time.
According to the BBC, around 200,000 abortions are carried out in the UK each year.
A near-total ban exists here. The Eighth Amendment (1983) gives the foetus equal right to life as the mother. Abortion is banned in cases of rape, incest, or fatal foetal abnormalities. There is a sentence of 14 years in prison for anyone who has an abortion. Consequently, thousands of women every year travel abroad for an abortion, or break the law by taking abortion pills anyway. Across Ireland there’s a powerful legacy of Catholicism, and inevitably deeply-held religious beliefs over the right to life. The Eighth Amendment itself has drawn much criticism, the UN and Amnesty International included.
The Protection of Life During Pregnancy Act (2013) defined circumstances under which abortion can be legally performed, allowing for the risk of loss of life of the mother from physical illness and from suicide, both of which must be agreed upon by at least two medical practitioners.
A referendum on Ireland’s abortion laws will take place in 2018 as Ireland considers reform of the Eight Amendment.
Rest of Europe
Abortion is generally allowed across Europe with some restrictions.
In Poland, however, abortion is mostly banned, unless there is severe and irreversible damage to the foetus, a serious threat to the health of the mother, or the pregnancy is the result of rape or incest. Far more illegal than legal abortions occur and access to over-the-counter contraceptives has also tightened. In 2016, an almost complete ban was passed, causing impassioned protests.
South America is one of the most restrictive regions of the world in terms of abortion.
Abortion was illegal without exception in Chile until August this year. Then a law legalised it when the woman’s life is at risk, the foetus will not survive pregnancy and in case of rape.
In Brazil, abortion is only permitted if the pregnancy puts the life of the mother in danger or if it’s the result of rape. The punishment for a woman who obtains an abortion outside of these rules is 1-3 years detention. In Venezuela and Paraguay it’s only legal if the woman’s life is in jeopardy.
Uruguay is one of the few places in South America to have fairly liberal abortion laws, permitting on request in the first 12 weeks.
In North America abortion law varies across the countries.
It’s a hotly contested issue in the USA, with availability varying hugely by state. The main people in the abortion debate tend to label themselves either ‘pro-life’ or ‘pro-choice’. President Trump’s views on the matter have been inconsistent, although he has banned any US funding to any overseas agency that even discusses abortion.
Abortion in Mexico is also controversial and varies state by state. In Mexico City it’s offered on request to any woman in the first 12 weeks, but is severely restricted in most other states.
Canada is one of only a few nations with no legal restrictions on abortion.
Middle East & Africa
Abortion is unsurprisingly heavily restricted in these parts of the world.
Countries such as Afghanistan, Iran, Iraq, Saudi Arabia and Syria only sanction it in cases such as risk of life to the mother or foetal impairment, while in Africa, only South Africa and Mozambique allow abortion in a variety of situations.
Across central Asia, abortion is generally permitted in a variety of circumstances.
In China, abortion is legal and available upon request. Although in theory this doesn’t apply to sex-selective abortion, this is still the basis for some women. Abortion was a common way for China to contain its population in accordance to its one-child policy that existed from 1979 to 2015.
In North Korea the phrase ‘important reasons’ seems to be the basis for its policy, effectively allowing it in the majority of cases. However, there have been reports of forced abortion in prisons from escapees.
South Korea, on the other hand, prohibits abortion unless in case of rape, incest, severe genetic disorders or risk to the mother’s life.
In Australia, abortion is a matter of state law, not national law, but in every state it’s legal to protect the life and health of the woman.
Finally, in New Zealand, abortion is only permitted if there’s a threat to the life, physical or mental health of the woman, or if there’s a risk of the foetus being born handicapped if the pregnancy is continued. Any other cases are illegal.