Abortion Law in Other Countries Not surprisingly, the state of the law varies considerably in different countries. We are indebted to the W.H.O. International Digest of Health Legislation for the information on nine European countries on which these notes are based, and must apologise in advance if our attempts to summarise this have led to any misconceptions. For facilities for studying the Digest we are indebted to the office of the World Federation for Mental Health; information about Sweden was supplied by the Swedish Institute for Cultural Relations. The countries were Finland, Denmark, Sweden, East Germany, Poland, Hungary, Czechoslovakia, Bulgaria and Yugoslavia : and thus offers an interesting comparison between the Scandinavian countries, and those with Communist governments. (For the provisions made in the U.S.S.R. see Miss McClellan's article, p. 107.) Speaking broadly, there are four major reasons for considering termination : they are, where pregnancy (a) is likely to damage the mother's health, or (b) following violence, or (c) is likely to result in a child with a hereditary disease, or (d) constitutes an intolerable social strain. The importance allowed to these various grounds differs considerably from country to country, as of course do the various factors within these groups. But certain points are of interest: Group (a), where pregnancy is likely to endanger the life or health of the mother, is a ground for termination in all the nine countries listed. In these, health seems indivisible and psychiatric indications seem as legal as any other medical indication : which would indeed seem logical. Yet in this country, psychiatric indications are looked at askance by many doctors who accept physical. (b) Pregnancy following rape can be terminated in Finland, Yugoslavia, Poland, Denmark, Czechoslovakia and Sweden. It will be recalled that Mr. Bourne brought a case, with much courage, to test whether such termination was valid in England, but in fact this did not clarify this issue, for the case was held to come under the heading of termination for medical reasons, and no clear precedent was laid down. (c) The possibility of severe hereditary disease is accepted as a reason for termination in Finland, East Germany, Yugoslavia, Denmark and Sweden, and in these cases it is sometimes laid down that sterilisation must be performed as well. (d) Social factors, not necessarily producing a psychiatric breakdown, are allowed as grounds for termination in several countries, but when this is so, strong recommendations are made to the responsible authority to try to persuade the patient to continue with the pregnancy. This is so in Poland, Sweden, Denmark ("in a very 102

special ease"), Czechoslovakia and Hungary. Bulgaria alone in this list (but, it is believed, like the U.S.S.R.) allows a woman to apply

to end a pregnancy she does not want. The termination must, however, be in a gynaecological hospital, and not after three months. Here, too, attempts are made to persuade the mother to continue the pregnancy, by propaganda, and by personal counselling. It may also be noted that even in the countries where legal termination is less restricted than in England, it is prohibited? sometimes with severe penalties?after the third month, except if the mother's life is in danger. It has been suggested that to make abortion easier and legal will increase the number of illegal abortions, Dr. O'Sullivan and Dr. Fairfield make this point, and claim that there is strong opinion in Russia, Japan, Denmark and Sweden that this has occurred, their argument being that more women engage in irregular sex relationships confident of an easy way out if pregnancy should ensue. But why in that case they should not use the easy way out, but turn instead to something known to be dangerous, seems obscure. There is also considerable variation as to who is to take the vital decision. In Finland, for example, two doctors must agree, one being specially appointed : in Yugoslavia, it is a board attached to a gynaecological unit: in Sweden, it is a National Board : in Czechoslovakia, a committee which appears to include a trustworthy and respected laywoman : in Poland (apparently), the medical committee of the hospital. R.F.T. There is food for much thought in all this.