While Niketa Mehta’s abortion plea has raised questions about India’s Medical Termination of Pregnancy (MTP) Act, the legislation passed in 1971 was much advanced for its period of formulation. It was also before most countries had such a law:•US: The pro-choice vs pro-abortion debate is an old one in the US and also figures in election campaigns. The landmark case was the 1970 Roe vs Wade, when attorneys filed a suit on behalf of Jane Roe who claimed her pregnancy was the result of rape. Overturning a Texas interpretation of the law, the Supreme Court in the case made abortion legal and held that a woman, with her doctor, could choose abortion in earlier months of pregnancy without restriction and with restrictions in later months, based on the right to privacy. The US Supreme Court went on to strike down several state restrictions on abortions in a long series of cases stretching from the mid-1970s to the late 1980s, but upheld restrictions on funding. Now most of the states in the US allow medical termination of pregnancy till the 24th week. •FRANCE: During the Nazi occupation during World War II, abortion was made a capital crime. While this was abolished after the War, women went in droves to the UK after it legalised abortion in 1967. France legalised abortion in 1975, available on demand until the 10th week of pregnancy. After the 10th week, two physicians must certify that a woman’s health is endangered or the foetus is handicapped. France was also the first country to legalise the use of pill for abortion in 1988, allowing its use up to seven weeks of pregnancy. •AUSTRALIA: Abortion after 20 weeks is allowed if two medical practitioners of a panel of at least six appointed by the health minister agree that the mother or the unborn child has a severe medical condition that justifies the procedure. In 1993, the Australian Health Act was amended to provide for abortion to be performed by a registered medical practitioner in a ‘medical facility’.•UK: Abortion has been legal in England, Scotland and Wales since the Abortion Act passed in 1967. However, it remains illegal in Northern Ireland. The Act allows a woman to receive an abortion to save her life, to prevent grave permanent injury to her health, and to avoid injury to her or her child’s physical or mental health, but before 28 weeks. The time limits were lowered from 28 weeks to 24 to reflect improving medical technology.•CHINA: Under its one-child policy, the ntional law instructs doctors to recommend abortion whenever the baby has a serious hereditary disease, a “serious deformity” or the pregnancy endangers the mother’s health. It also has a forced abortion policy, with the concept of “illegal pregnancy”. The policy requires that parents with two children be sterilised and a woman pregnant with a third child be forcibly aborted.•CANADA: There are no legal restrictions on abortion. However, prior to 1969, it was an offence liable with life imprisonment. In 1969, a provision made an exception for abortions performed in a hospital with the approval of its three-doctor therapeutic abortion committee. •IRAN: The Iranian parliament ratified the Therapeutic Abortion Act on June 21, 2005. Iran permits termination of pregnancy within 16 weeks if the foetus is mentally or physically handicapped or if the mother’s life is in danger. The woman’s consent is sufficient to carry out the abortion. However, three specialists must confirm that the foetus is disabled or the mother has a life-threatening condition.•OTHERS: Countries in which abortion is normally illegal will allow one to be performed in the case of rape or danger to a woman’s life or health. A few nations like Chile, El Salvador, Ireland and Nicaragua ban abortion entirely.
