Abortion often invites exuberant debates amongst the intelligentsia. The general question around which the discourse revolves is of morality, women's right, the life of foetus and state’s authoritative role in regulating the women’s reproductive rights. Women in many parts of the world still do not have basic human rights. The problem with regulating abortion is to find a balance between an ever-increasing degree of medical empiricism that time and technology continually bring into the domain of modern society.

The stigma and shame associated with abortion – A negative attribute got attached to a woman who seeks abortion due to religious beliefs, cultural values, and economic status - lead several unwed women to seek unsafe abortion services outside health facilities.

During the last few years, many countries have liberalized their abortion laws. Many countries are having very restricted abortion laws while there are countries where abortion is available at the request of woman.
Among all those countries India made the abortion laws liberal in 1971 by enacting Medical Termination of Pregnancy Act which was designed to create certain exceptions to the strict provisions of Penal code and Pre-natal diagnosis Act 1994. Despite its liberal abortion law, it does not compute 'choice' as a factor for abortion.

Human rights experts and national lawmakers should promote the removal of provider involvement requirements from abortion laws so that the world's poorest and most marginalized women can exercise their rights to health and life and fully realize the promise of medical abortion.

What Is Abortion?

Abortion in its literal sense means "expulsion of the fetus before it is viable." This could include spontaneous abortion i.e. miscarriage or induced abortion, Which can be done with the help of a doctor or by the women herself. In pre industrial societies, hitting the pregnant woman in the abdomen over the uterus and jumping on her abdomen were some of the common techniques used to induce abortion[1].

Abortion is one of the most controversial subjects in modern Society. The Dalai Lama has stated that it is a negative process with exceptions approved or disapproved according to each circumstance.[2].The principal controversy revolves around the questions of who makes the decision concerning abortion — the individual or the state; under what circumstances it may be done; and who is capable of making the decision. Medical questions such as techniques of abortion are less controversial but are sometimes part of the larger debate.

There’s a difference between miscarriage and abortion. A miscarriage is a natural or spontaneous termination of a pregnancy, meaning the body expels the pregnancy on its own without the aid of medicine or a surgical procedure. Abortion occurs when a procedure is done with the purpose of ending a pregnancy.

Reasons For Abortion

There are probably as many reasons for abortions. Some pregnancies result from rape or incest, and women who are victims of these assaults often seek an abortion. Many young women in high school or college find themselves pregnant and must choose between continuing the education or dropping out to have a baby. Young couples prefer to develop financial security first to provide better care for their future children. Abortion is sometimes sought because a woman decides that the social status of the male is inappropriate.

Some of the most difficult and painful choices are faced by women who are happily pregnant for the first time late in the reproductive years (thirty-five to forty-five) but discover in late pregnancy that the fetus is so defective it may not live or have a normal life. Even worse is a diagnosis of abnormalities that may or may not result in problems after birth. Some women and couples in this situation choose to have a late abortion.

Physical And Psychological Effects of Abortion

Studies of the long-term risks of induced abortion, such as difficulties with future pregnancies, show that these risks are minimal. A properly done early abortion may even result in a lower risk of certain obstetrical problems with later pregnancies.[3]If the abortion permits postponement of the first-term pregnancy to after adolescence, the usual risks associated with a first-term pregnancy are actually reduced.

Psychological studies consistently show that healthy women with strong emotional support not only from friends and family but also from a sympathetic physician can handle the outcome of pregnancy. On the other hand, women who have received hostile, punitive messages about the pregnancy and the decision to have an abortion are likely to experience high levels of stress during the abortion and may have a lingering sense of guilt for having decided to follow through with the abortion procedure.

Pro-Life And Pro-Choice Advocates

> People who are pro-choice believe that women should have the basic human right to decide when and whether to have children, based on their own moral and religious beliefs.
People who are anti-choice oppose abortion. Many of them do not believe that a woman should be able to choose abortion under any circumstances, even if she has been raped or if carrying the pregnancy to term may put her life in danger. Also, they are against birth control.

Anti-choice people often call themselves Pro-life. But the only life many of them are concerned with is the life of the fertilized egg, embryo, or fetus. They are much less concerned about the life of women who have unintended pregnancies or the welfare of children after they are born because they feel thatabortionis evil because it is killing an unborn child.

Development of Abortion Laws Across The World

Abortion is a common experience around the world, it is still largely stigmatized. Negative attitudes and beliefs about abortion may act as barriers to accessing safe services and can make it difficult for people to talk about their experiences of abortion. This can lead to seeking an unsafe abortion. Though stigma manifests differently depending on geography, culture, and religion, abortion remains a contested issue in countries as different as Australia, Spain, the United States, and Kenya.

Legal system to restrict Abortion was developed during the period of colonialism from the sixteenth century onward and these restrictions on abortion were introduced for three main reasons:
1. Abortion was dangerous and abortionists were killing a lot of women.
2. Abortion was considered a sin or a form of transgression of morality.
3. Abortion was restricted to protect fetal life in some or all circumstances.

Various Legislations Related To Abortion

Many governments struggle to strike a balance between the rights of pregnant women and the rights of unborn fetuses. This often leads to complex policies governing when and under what circumstances a woman may legally have an abortion.

Alexandra Kollantai, a feminist who reformed the abortion laws in the Soviet Union and made it the first country to order a decree on women’s health care in October 1920. Since then, progressive abortion law reform (the kind that benefits women) has been justified on public health and human rights grounds.

Canada is the only country in the world which legalized abortion at any stage of pregnancy. After the Supreme Court of Canada in 1988 upheld the existing abortion laws as unconstitutional.
Latin American countries like Brazil, Chile have legalized abortion and ruled that these procedures can only be performed in cases in which the mother’s life or physical health is in danger, in cases of rape or incest, or in pregnancies involving life-threatening fetal abnormalities.

Most of the European countries permit abortion for a variety of reasons if certified by physicians. Within the first 12 or 24 weeks of pregnancy, these reasons may include: to save the life of the mother, to protect her physical or mental health, to abort on the grounds of Fetal abnormalities or for social or economic reasons.

Countries in both the Middle East and Africa allow Abortions during the first trimester and after 12 weeks when the mother’s physical or mental health is at risk and in cases of fetal abnormalities; however, In more traditional communities, doctors may be less willing to perform abortions in situations that are considered taboo, As a result, women often resort to illegal abortions.

While Asian countries like China and Japan promoted Liberal policies related to abortion wherein Abortion is virtually freely available in China, and there are no defined time limits for access to the procedure. Whereas regulations in Japan make abortion legal within the first 24 weeks of pregnancy to save the mother's life or to protect her physical health.

Restricting Abortion Without Any Lawful Justification

Decent laws and policies can be sabotaged and access to abortion can be restricted without amending the law itself, Bureaucratic obstacles may be placed in women's paths, such as requiring unnecessary medical tests, counseling even if women feel no need for it.

Women have therefore begun to take matters into their own hands. An uncounted number of women, probably in the millions, has been obtaining and using misoprostol to self-induce abortion from a range of sources—pharmacies, black markets. This practice, begun in Brazil has spread to many other countries and regions. .
In response, legal restrictions and regulations on access to medical abortion pills have been imposed by countries such as Brazil and Egypt in an effort to stop the unstoppable.

Law Reforms For The Better
Cuba was the first country in Latin America and the Caribbean to reform its abortion law in favor of women, with a law that remains unique. Since 1965, abortion has been available on request up to the tenth week of pregnancy through the national health system. The Penal Code, adopted in 1979, says that abortion is considered illegal only if it is without the consent of the pregnant woman, is unsafe, or is provided for profit.
Canada and Sweden have effectively proved that no criminal law is feasible and acceptable and even abortions after 18 weeks can effectively disappear with good services, support and health care of the women.

World Health Organization (WHO) Guidelines

Abortion is one of the safest medical procedures if done following the World Health Organization’s (WHO) guidance. WHO guidelines also point out that when women who do not have access to sexual and reproductive health services and information, including contraception and safe abortion care, they are at risk of unsafe abortion.[4]

But to achieve these goals, it takes a strong and active national coalition, a critical mass of support, to make change happen on the ground. Thus, the availability of safe abortion depends not only on permissive legislation but also on a permissive environment, political support, and the ability and willingness of health services and health professionals to make abortion available.

Violation of Basic Human Rights
No woman can call herself free until she can choose consciously whether she will or will not be a mother. - Margaret Sanger, founder of Planned Parenthood
Women's organizations across the world have fought for the right to access safe and legal abortion for decades, and increasingly international human rights law supports them claims. It's the women who get pregnantand also suffers when abortion rights are restricted.

The Committee on Economic, Social and Cultural Rights and the Committee on the Elimination of Discrimination against Women (CEDAW) have both clearly indicated that States have obligations to provide rights related to women’s sexual and reproductive health[5].

Despite these obligations, Violation of women’s sexual and reproductive health rights is very common. Denial of access to good health care services, or by Imposing oppressive laws making it more difficult for women to get a safe and legal abortion.

Basic Human Rights
Violations of women’s sexual and reproductive health rights are often deeply ingrained in societal values pertaining to women’s sexuality. The role of women in the Patriarchal society is based on their ability to reproduce. Women are also often blamed for infertility, suffering ostracism and beingsubjected to various human rights violations as a result.

Some basic human rights available to women are:
1. Women have moral rights to decide what to do with their bodies.
2. The right to abortion is vital for gender equality.
3. Banning abortion puts women at risk by forcing them to use illegal abortions or unsafe abortions.
Thus, we should regard the woman as a person and not just as a container for the foetus.

Autonomy
Autonomy means the right of a woman to make decisions concerning her fertility and sexuality free of coercion and violence. Much turns on our understanding of coercion and violence. "Autonomy" also means that a woman seeking health care in relation to her fertility and sexuality is entitled to be treated as an individual in her own right - the sole client of the health care provider, and fully competent to make decisions concerning her own health. This is a matter, among other things, of the woman’s right to equality before the law as to her legal capacity.

The Right To Life
Discrimination against women is a significant factor in the high numbers of deaths and complications related to pregnancy and childbirth. It is the Government's obligation to provide access to affordable quality health services that would prevent maternal mortality.Maternal mortality and morbidity can largely be avoided through the provision of reproductive health services, including contraception, safe abortion. The most obvious human right violated by avoidable death in pregnancy or childbirth is women’s fundamental right to life itself.

Post Abortion Condition Of Women
Post-abortion care (PAC) is the treatment given to a woman who presents at a health center or hospital with complications, usually bleeding or infection, due to an incomplete abortion or miscarriage. Medical care, including medication or surgery, is given to the woman to evacuate the uterus and to save her life.

Post-abortion medical services must always be available, safe and accessible regardless of the legality of abortion, humane post-abortion services must be provided, including guidance on contraceptive methods to avoid unwanted pregnancies.

Vulnerable Situation of Women
Health practices and policies should be examined in light of the needs of Different groups of people in society. These include rural and marginal urban groups, women in situations of armed conflict, and women in prostitution.

Alabama a state in the U.S.A where women’s health outcomes are determined by race, economic class, and geography has recently passed adraconian abortion law criminalizing abortion and attempted abortion. Any attempt to carve out an exception for the victims of sexual violence were rejected.

This cynical bill doesn’t even pretend to address the real health needs of Alabamian women. Instead, it seeks to control women and girls’ bodies against their will.
It can be summarized as violations of one of three major human rights concepts - liberty, social justice and equality. The principle of liberty is key to notions of civil and political rights, while the principle of justice is key to notions of economic and social rights. The principle of equality is an overriding one.

Abortion Policy In India: A Discourse On The Past And The Future
The United States and other developed nation shave moved ahead with the various issues of constitutionality versus individual rights which seems to be creating a new era of debates. In India, the scenario is totally different as the pro-life and pro-choice debates were avoided here due to the active involvement of the state in curbing the increasing population rates.

The Medical Termination of Pregnancy Act(hereinafter referred to as MTP Act) came into force from April 1, 1972. Provisions regarding abortion date back even earlier with the incorporation of provisions regarding abortion law in the Indian Penal Code which was enacted more than a century ago. These were drafted at that time, keeping with the then existing sensibilities of societal requirements and in consonance with the British Law on abortion.

One of the reasons for large scale violation of abortion law is its severity and repressive nature. Section 312 to 316 of the Indian Penal Code deals with the offenses affecting the human body. The Penal Code permits abortion only for the preservation of the life of a pregnant woman.

Another problem with the enforcement of abortion law is the non-cognizable nature of the offenses under the Penal Code. Police cannot act unless there is a complaint. No complainant comes forward because the woman who is, in fact, the victim is also the beneficiary.

Controversies Related To The MTP Act
The MTP Act, though appears to have been enacted for control of population in India actually provides for the termination of certain pregnancies by Registered Medical Practitioners (RMP) for protection and preservation of the lives of women. Abortion policy in India is consistent with safeguarding reproductive rights as envisaged by the International Conference on Population and Development (ICPD)[6]and similar other international agreements. It was enacted to recognize the importance of providing safe, affordable, accessible and acceptable abortion services to women with an unwanted pregnancy.

The validity of the MTP Act was challenged as late as 2005 in the case of Nand Kishore Sharma v. Union of India[7]. It was argued that the Act, particularly Section 3(2)(a) and (b) and Explanations I and II to Section 3 of the Act were unethical and violative of Article 21 of the Constitution of India. The Court in the case had to determine when the fetus actually comes to life and hence if his or her right to life is violated by the said provisions. The court declared the MTP Act to be valid as it was in consonance with the aims and objectives of Article 21 of the Constitution rather than against it. However, the Court took an ambivalent stance saying that it was difficult to determine exactly when a fetus comes to life and hence avoided a closure on the matter.

Further In Nikita Mehta case[8]the Court categorically stated that even if this petition had been made before the 20 weeks had elapsed, the Court would still not have found in favour of the petitioners as the requirements of provisions of law under Section 3(2)(ii) read with Section 3(2)(b) are not satisfied.

Prenatal Diagnostic Techniques: A Boon Or A Bane?
It remains an unfortunate fact that even in this modern era of developments in education, science, and technology, the girl child is being discriminated as against the boy child. Parents prefer to have only sons and therefore they either allow many issues until the desired son is born or they prefer to abort the foetus of a girl child after identifying by the sex determination tests. thus discrimination against the female child, obvious at all stages of life starts even before she is born. Advances in Medical Science like Prenatal Diagnostic technique (PNDT) are misused to detect the sex of a foetus and MTP Act is abused to get rid of a girl child before birth. Such abuse of medical science is a crime against the female sex, diminishing the dignity and honor of a woman.

The Pre-Natal Diagnostic Techniques Act (herein referred to as the PNDT act) was passed in July 1994. The PNDT Act was meant to be a significant step to counter the widespread use of prenatal diagnostic techniques, which would lead to subsequent abortion of female fetuses. women's groups and social activists targeted sex determinative tests and not sex-selective abortions because access to abortions services are liberalised under the Medical Termination of Pregnancy Act, 1971, the right to abortions is not recognised under Indian law. Hence, it was considered that imposing additional conditions on obtaining abortions would further limit a woman's access to abortion services.

The objective of the PNDT Act was, therefore, two-fold. First, to regulate pre-natal diagnostic techniques and limit it to the detection of genetic or metabolic disorders. Secondly, to prevent the use or rather misuse of such technology for the purpose of pre-natal sex selection this, in turn, would lead to sex-selective abortions.

Unfortunately, nothing significant was done to implement the act and it was avoided until a Public Interest Litigation was filed, The Hon'ble Supreme Court passed a favourable interim order in May 2001 directing the Central Government and states to take all necessary steps to implement this law.

The Central Government after the directions of the Supreme Court tabled an amendment to the Act. The amendment Act was finally passed on February 14, 2003. The PNDT now stands converted to the "Pre-Conception and Pre-Natal Diagnostic Techniques (Prohibition of Sex Selection) Act (PCPNDT)".

The objective of the Government to amend the act are as follows:
# To ban the pre-conception sex selection techniques.
# To prohibit the misuse of pre-natal diagnostic techniques for sex-selective abortions.
# To regulate the pre-natal diagnostic techniques for the appropriate scientific use for which they are intended.
# To ensure the effective implementation of the Act at all levels.
# The Act provides for compulsory registration of all Diagnostic Laboratories.

Conflict Between Laws
There is a lack of understanding among stakeholders and serious conflict in the framing of the MTP Act, the Pre-Conception and Pre-Natal Diagnostic Techniques (PCPNDT) Act, 1994.

For instance, officials carrying out stringent inspections to curb sex determination under the PNDT, often clamp down on MTP centres and gynaecologists legally qualified to provide abortion services. It is a similar case with the POCSO Act, which mandates that the service provider register a complaint of sexual assault with the police if a girl under 18 has sought an abortion. Given that between 45 and 47 per cent of girls get married under 18 years of age in India, this turns out to be a barrier for young women seeking an abortion.

Multiple PILs in this regard, explains that according to the PCPNDT Act, one can abort within 8-12 weeks, which further leads to sex-selective abortions. it should not be confused with the MTP Act as someone wishing to abort in general wouldn’t wait for 20 weeks to find out if they want a baby boy or girl.

It must be understood that the time period for two is different but they don’t necessarily have to overlap since someone who wants a sex-selective abortion would know from the very beginning and won’t exactly wait for 20 weeks as is the case under the MTP Act, More than the denial of abortion, the result of such grey areas is unsafe abortion services by unregistered providers, which places the lives of several women and newborns at risk.

Streamlining of the three laws should, therefore, be one of the foremost steps to enhance access to safe abortion services to women and guarantee them their health and human rights.

Initiative To Make Abortion Accessible
The MTP (Amendment) Bill, 2016, did propose certain amendments targeted at reducing procedural barriers for abortion services. It proposed increasing the abortion time limit and removing the limit altogether for pregnancies diagnosed with substantial fetal abnormalities.

The efforts were, however, halted after investigations into the death of a woman in Maharashtra from an unsafe abortion performed by an unregistered provider uncovered evidence of sex-selective abortions being performed in the same facility.

With no indication of any initiative from the legislature and petitions being filed across the country, the onus now seems to lie on the judiciary to strike down the 20-week limit on scientific and constitutional scrutiny of the provision. Human Rights Law Network, feels it is important for the Supreme Court to take up the main petition regarding the time limit, instead of frequent adjournments, as this is why so many women keep moving court with respect to their abortion pleas.

It is essential that India sets the record straight and takes a stand for upholding women’s reproductive rights especially when developed countries are now vacating the pedestal to adopt regressive and oppressive laws.

Critical Analysis Of Indian Law
The MTP Act does not define 'health', 'substantial risk', 'seriously handicapped' and so on. Although two explanatory notes indicate that pregnancy in the case of rape (excluding marital rape) and contraceptive failure (in the case of a married woman) may be treated as causing injury to mental health. In fact, even the words 'abortion', 'miscarriage' and 'termination of pregnancy' have not been defined, which leaves the medical opinion on these matters sacrosanct.

According to 376 C of the Code by the Criminal Law (Amendment) Act 2013, sexual intercourse by a man in authority with a woman not amounting to rape have been made punishable. If pregnancy is caused by such an act she cannot get it terminated. Also, S.376B of the Code fails to take note of a special situation where the husband and wife are living separately under a decree of judicial separation by mutual consent. In such a situation, marriage subsists in law, and if the husband has sexual intercourse with his wife against her will and consent, neither the husband can be convicted for the offence of rape nor the wife can go for abortion.

Other problems related to the current MTP act which needs to be significantly amended:
Provisions of MTPA and Hindu Marriage Act in conflict: In Sushil Kumar v Usha, 70 the wife got the foetus aborted in accordance with the provisions of the MTP Act without her husband's consent. A petition for divorce was filed by the husband's consent. A petition for divorce was filed by the husband's on the ground of cruelty and the Delhi High Court passed the decree of divorce. The married woman who had done a legal thing under the MTP Act became victimized. It clearly reveals that the provisions of the MTPAct and the Hindu Marriage Act are in conflict. Thus, to get the pregnancy terminated under the MTP Act husband's consent is not mandatory.

The Act does not define the phrase 'grave injury to the physical and mental health of the pregnant woman' contained in s. 3(2)(b)(i) of the Act. The definition is inclusive i.e. includes certain events under which the pregnant lady may be deemed to have suffered from a grave injury to her mental health.

. The MTP Rules define person and place requirements, but do not refer to any national or international technical guidelines for safe abortion care. In the absence of such linkages with guidelines for good clinical practice, providers continue to use unsafe abortion practices.

While the MTP Act permits women to seek legal termination of an unwanted pregnancy for a wide range of reasons, the clause about contraceptive failure applies only to a married woman. The critique in this perspective would be that the focus of safe abortion care has been traditionally for women who are married, implying a denial of such care to an unmarried woman in need of terminating an unwanted pregnancy.

Abortion Laws In 21st Century
The better educated an individual; the more likely they were to approve of a woman’s right to have an abortion.
The World Health Organization (WHO) estimates that due to the Unsafe induced abortions and accessibility to the health care services are responsible for the death of almost half a million women in developing countries. .

United States: The Progressive Country
Abortion has been a controversial issue in the USA, as the states controlled by the Republicans having a conservative ideology call for a ban on abortions whereas the Democrats having a liberal ideology call for lifting of regulations on abortions.
The country is lauded for its pro-liberty stance on the rights of citizens. However, the state of Alabama in the USA is in the news for passing legislation that curbs liberty and autonomy of women, by banning abortion even in cases of rape and incest (except in cases where there is a serious health risk to the mother). The Bill although does not make the woman criminally liable for the abortion, it carries imprisonment up to 99 years for the doctor performing it.

Abortion Laws In U.S.A
States in the USA have greater leeway in making legislation that governs them. Abortion has been an area where state governments have made respective state legislation to govern the procedure. Till 1973, few states in the USA permitted abortion whereas the others termed it illegal in all circumstances. However, the position changed with the decision of Roe v. Wade in 1973.

Roe v. Wade-
It should be noted that central to the debate surrounding legality of abortion is the argument ofautonomy versus life. The side which argues for legalizing abortions believes that women should have the autonomy to take their medical decisions including whether to give birth to a baby or not, whereas the other side argues on the lines of protection of 'life' which includes a prenatal life as well. The US Supreme Court in Roe v. Wade had to choose between these two arguments

The Court, however, stopped short of making the right absolute and called for balancing the right with the state's interest to protect life. The test provided by the Court is as follows (called the trimester test):
# During the first trimester (1-12 weeks), the right to termination is absolute and the government could place no restriction on the same, barring minimal medical safeguards.
# During the second trimester (13-28 weeks), the government can make regulations aimed at protecting the health of the women.
# During the third semester (28 weeks onwards) the government can legally prohibit all abortions except where necessary to protect the mother's life and health.
The rationale behind the test is the safety of the mother. In the first trimester, abortion is considered safe. In the second trimester, the risk to mother's health increases, whereas in the third, abortion is dangerous to the woman's health.

Fate of Alabama’s Legislation
Banning abortion does not stop abortion. It stops safe abortion.
The Alabama legislation makes it a crime to perform an abortion on a woman at any stage of pregnancy i.e. pre or post viable foetus barring the exception. The legislation goes against the decision in Roe.
It is another way to intrude into women’s lives and terminate their rights. It puts women’s lives in the hands of law enforcement and entangles medical decisions with bureaucracies and regulations.

A 20th Century Debate In A 21stcentury Reality
The debate should be different than it was in 1973. Women don’t want to keep having an outdated 1973 conversation about abortion given 21st Century medical advances and a lack of social stigma about nontraditional pregnancy timelines and circumstances. Thetolerance for legal 2ndtrimester abortions is gone because women consider them “viable” Even the last decades of 20th century saw severe cuts in social programs designed to aid low-income mothers and their children, cuts to funding for public education and housing, court decisions that dramatically reduced poor women’s access to reproductive health care including abortion.
The Reproductive Justice movement, which would become increasingly influential in the 21st century, defined reproductive health, rights, and justice as a human rights due to all persons and articulated what each individual requires to achieve these rights: the right not to have children, the right to have children, and the right to the social, economic, and environmental conditions necessary to raise children in healthy, peaceful, and sustainable households and communities.

Conclusion
Right to life and personal liberty is the heart and soul of the wider field of law called the human rights. In society lesser evil is promoted in the larger societal interest. Here comes the law as supreme savior, which should be pragmatic and generally acceptable to the useful part of society. Laws on sexual practices are quite often least realistic. Countries across the world today are witnessing a plethora of cases with a reproductive issue as abortion, but are not specifically denominated. Treating abortion as essential health care is a major step forward like placing first-trimester abortion care at the primary and community level, ensuring second-trimester services, involving mid-level providers, increasing women’s awareness of services and the law, aiming for universal access, integrating WHO-approved methods. But to achieve these goals it takes a strong and active national coalition and a critical mass of support.

In India Increasing awareness and dispelling misconceptions about the abortion law amongst providers and policymakers is just one step towards this. There is a need to enhance awareness of both contraceptive and abortion services, especially amongst adolescents, within the larger context of sexual and reproductive health, integrating strategies and interventions within value systems and family and gender relations. Due to the competing rights in the debate i.e. autonomy v. protection of life, an 'absolute' approach of one over the other, would lead to no fruitful result. Therefore, a harmonious balance needs to be maintained. The Court in Roe achieved that balance, by promoting a woman's autonomy in pre-viability stage and protection of prenatal life post-viability stage. Andto fulfill the human right of all individuals and couples to decide freely and responsibly on the number, spacing and timing of their children, it is essential that governments guarantee access to quality reproductive health information and services, including safe abortion care.

End-Notes
[1]Early, J.D., and Peters, J.F. (1990).The Population Dynamics of the Mucajai Yanomama. San Diego: Academic Press
[3]Hodgson, J. (1981).Abortion and Sterilization: Medical and Social Aspects. London: Academic Press
[4]Van Look, P. and Cottingham, J. (2013). The World Health Organization’s Safe Abortion Guidance Document. American Journal of Public Health, 103(4), pp.593-596.
[5]Felice, W. (2002). The UN Committee on the Elimination of All Forms of Racial Discrimination: Race, and Economic and Social Human Rights.Human Rights Quarterly, 24(1), pp.205-236.
[6]Ghabbour, S. (1994). United Nations International Conference on Population and Development (ICPD), held in the International Conference Centre, Cairo, Egypt, during 5–13 September 1994.Environmental Conservation, 21(3), pp.283-284.
[7]Nand Kishore Sharma And Ors. vs Union Of India (Uoi) And Anr,( 2005),WLC Raj UC 411
[8]Madhiwalla, N. (2008). The Niketa Mehta case: does the right to abortion threaten disability rights?.Indian Journal of Medical Ethics.