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2005/09: Should the federal Government attempt to limit or remove access to late-term abortions?

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2008/21: Should the Victorian Government remove abortion from the Crimes Act?

2008/21: Should the Victorian Government remove abortion from the Crimes Act?


What they said...
'We will have a situation in this country when in one part of a hospital babies will be in humidicribs being kept alive and in some other part it will be legal to be aborting them'
Peter Costello, former deputy leader of the Liberal Party and former federal treasurer

'Women have the intellectual and moral capacity to make decisions about their own fertility'
Julian Burnside, QC, President of Liberty Victoria

The issue at a glance
On September 10, 2008, a bill titled the Abortion Law Reform Bill, was passed by the Legislative Assembly, the lower house of the Victorian Parliament.
The state's lower house voted to approve the second reading of a bill to provide unrestricted access to abortions up to 24 weeks' gestation and to remove unlawful abortion from the Crimes Act.
Opponents of the Bill attempted unsuccessfully to attach a series of amendments to require, among other things, mandatory counselling and opt-out provisions for health workers who oppose abortion.
The Bill was put to a conscience vote. Forty-seven members of parliament voted in favour of the bill and thirty-five against. The ballot in the upper house (the Legislative Council) is expected to be significantly closer.
The Bill has sparked significant debate in the community on the issue of abortion and how it should be accessed.

Background
Current abortion law in Victoria
Abortion law in Victoria is currently governed by Sections 65 and 66 of the Crimes Act 1958 which make it a criminal offence for a woman to unlawfully procure her own miscarriage and for any other person to procure or assist with the procurement of a miscarriage.
Prior to the Menhennitt ruling in R v Davidson (1969) necessity was not considered ta defence to the charge of abortion in Victoria.
In R v. Davidson Justice Menhennitt ruled that an abortion was not illegal if it were performed with a reasonable and honest belief that the pregnancy was a serious risk to the woman's life or health. So in these circumstances, necessity became a defence to killing.
However, Menhennitt also ruled that the onus was on the Crown to prove there was no reasonable or honest belief on the part of the medical practitioner.
Since the Menhennitt ruling it is estaimated that some 20,000 abortions are performed in Victoria annually. There are those who dispute that all of these meet the standards criterion outlined by Menhennitt.

The Abortion Law Reform Bill 2008
Under the terms of the Abortion Law Reform Bill 2008 the following would pertain:

Termination of pregnancy could legally be performed by a registered medical practitioner at not more than 24 weeks' gestation.

A registered medical practitioner may also perform an abortion on a woman who is more than 24 weeks pregnant only if the medical practitioner-
* reasonably believes that the abortion is appropriate in all the circumstances; and
* has consulted at least one other registered medical practitioner who also reasonably believes that the abortion is appropriate in all the circumstances.

In considering whether the abortion is appropriate in all the circumstances, a registered medical practitioner must have regard to-
* all relevant medical circumstances; and
* the woman's current and future physical, psychological and social circumstances.

Supply or administration of drugs by a registered pharmacist or registered nurse-at not more than 24 weeks:-
A registered pharmacist or registered nurse who is authorised under the Drugs, Poisons and Controlled Substances Act 1981 to supply a drug or drugs may administer or supply the drug or drugs to cause an abortion in a woman who is not more than 24 weeks pregnant.

Internet information
In May 2008, the Victorian Law Reform Commission released its report on abortion law in Victoria, including three possible options, for bringing about abortion law reform in Victoria.
A summary of these options and an index of different elements of this report can be found at http://www.lawreform.vic.gov.au/wps/wcm/connect/Law+Reform/Home/Newsroom/Media+Releases/LAWREFORM+-+Final+Abortion+Report+tabled+%28media+release%29

The text of the Victorian Abortion Law Reform Bill 2008 can be read at http://www.legislation.vic.gov.au/domino/Web_Notes/LDMS/PubPDocs.nsf/ee665e366dcb6cb0ca256da400837f6b/3F1389267C60C2F4CA2574AA00087950/$FILE/561293bi1.doc

On September 5, 2008, The Catholic News published an article titled, 'Students attack Vic abortion bill "conscience clause"'.
The article argues that the provisions of the conscience clause in the Victorian Abortion Law Reform Bill require medical practioners and others who have a moral objection to abortion to refer a woman requesting an abortion to a practitioner who will provide one. It is claimed that this ignores the original practitioners' moral objections. The full text of this article can be found at http://www.cathnews.com/article.aspx?aeid=8850

A pastoral letter from the Catholic Bishops of Victoria opposing the Abortion Law Reform Bill can be found at http://www.melbourne.catholic.org.au/archbishop/pastoralletters/20080423_PastoralLetter_Abortion.pdf

Women's Health Victoria is an independent Victorian state-wide women's health promotion organisation. Their Internet site has a range of sub-sections outlining the current manner in which abortion is available in Victoria and urging abortion law reform in this state. It supplies a number of media releases on the issue and presents anti-abortion 'myths' which it then counters.
This site can be accessed at http://www.whv.org.au/topical/abortion.htm

Solidarity is a socialist group with branches across Australia. The socialist group has a website on which it published an article which indicates that while it supports abortion law reform it does not believe the current Bill goes far enough. The full text of the article can be found at http://www.solidarity.net.au/current/victorian-abortion-legislation-a-step-forward-but-restrictions-remain/

Arguments against making abortion legal in Victoria
1. The new bill legalises late-term abortion
There is concern that the new bill, in specifying that abortion can take place up to 24 weeks into a pregnancy has legalised late-term abortion. Under the terms of the Bill any woman may have an abortion on request, without having to demonstrate cause, up to when the pregnancy has advanced to six months.
This is concern at this because many in the community believe that abortion six months into a pregnancy is too late. This objection is based largely on viability. It is now possible to sustain the life of babies born at 24 weeks; therefore, to deliberately end the life of an unborn at this stage of development seems morally problematic to many.
The former deputy leader of the Liberal Party and the former federal treasurer, Peter Costello, has stated, 'I can't believe that there is a proposal to make abortion legal as a matter of course up to 24 weeks, when babies are born at less than 24 weeks. We will have a situation in this country when in one part of a hospital babies will be in humidicribs being kept alive and in some other part it will be legal to be aborting them.'
Costello has argued further, 'It should be looked at more both as a conscience issue and as a medical issue simply because it is possible to keep babies alive today at a very young age.'
There is further concern that under the Bill an abortion may be acquired after six months and apparently up to full term if two medical practitioners 'reasonably believe that the abortion is appropriate', with regard to 'all relevant circumstances and the woman's current and future physical, psychological and social circumstances'.
The Bill does not disallow partial birth abortion. Partial birth abortion occurs at or near term when a foetus is partially removed from the womb and then killed. At the time of writing this outline, the Bill had passed through the Legislative Assembly unamended. Amendments to prevent partial birth abortion were rejected.

2. The Bill does not allow freedom of conscience to medical practitioners who oppose abortion
Under the terms of the abortion reform Bill a doctor who has moral objections to abortion would generally be able to refuse to perform an abortion if requested; however, he or she would have to refer the patient to another doctor who would perform the procedure. The bill also requires that where the woman's life is judged at risk through a continued pregnancy, any doctor can be obliged to perform an abortion.
There are those who believe that this bill is an attack on doctors' right to act in accord with their conscience.
Patrick Giam, the Australian Catholic Students Association (ACSA) Media Officer, has claimed, 'Not only does this Bill attack the right to life, which all unborn children deserve, it also attacks doctors' freedom of belief. Even where doctors may have reasoned moral views against abortion, this Bill forces them to assist women to procure abortions and in some cases even perform it themselves. This is a deplorable attack on the freedom of our medical professionals.
Even the AMA Code of Ethics does not require a medical practitioner to refer a woman seeking abortion to another practitioner. This obligation in the Bill will compromise the ability of our doctors to act in a professional and morally responsible manner.'
Similarly, bioethicist, Nicholas Tonti Filippini has stated, 'Under Victoria's new Abortion Law Reform Bill 2008 , many Catholic health practitioners and institutions will find their practices under threat if they are unwilling to advise or perform an abortion or refer for abortion. The right to conscientious objection by professional health practitioners has been severely curtailed.
The Bill (section 7) extends the practice of abortion to permit a registered pharmacist or registered nurse who is authorised under the Drugs, Poisons and Controlled Substances Act 1981 to supply a drug or drugs may administer or supply the drug or drugs to cause an abortion in a woman who is not more than 24 weeks pregnant...
Under section 8, doctors, nurses, pharmacists and psychologists would have to refer for abortion if they were unwilling to advise or perform an abortion. Catholic institutions who require their health professionals to abide by their code of ethics will find it difficult to maintain their codes of ethics if the Bill is passed and professionals engaged in the institutions are obliged by law to perform or to refer for abortion.'

3. The Bill does not require counselling for pregnant women seeking abortion nor require other support provisions
Under the terms of the Bill, there is no requirement for a woman seeking an abortion to receive information or counselling. There is no provision for a cooling-off period, nor any restriction on where terminations can be performed. There are those who are concerned that this does not acknowledge the seriousness of the decision to have an abortion, nor the potentially harmful physical and psychological effects an abortion can have on a woman.
Bioethicist, Nicholas Tonti Filippini, noted with concern that the Law Reform Commission report, which the Victorian Government drew on in drafting its Bill, also rejected 'requirements for making counselling available, seeking an independent medical opinion, reporting adverse events or restricting abortion to places that have adequate facilities for a major surgical procedure.' Tonti Filippini's concern was that the potential adverse effects of abortion on women were being minimised and that there is not even a process in place for recording such adverse events.
Referring to the Law Reform Commission's report and by extension the Victorian Government's Bill which draws on it, the Catholic Archbishop of Melbourne, Denis Hart, has also noted, 'The Commission's Report fails to address the gravity of the decision for a woman and the adverse effects of abortion. The Commission's Report completely fails to address the needs of a woman in the predicament of an unexpected pregnancy for support and the opportunity to discuss the issues with someone who is supportive of her and independent.'

4.  The Abortion Law Reform Bill is not necessary
The Victorian Health Minister, Daniel Andrews, has stated that the Abortion Law Reform Bill was intended only to remove abortion from the Crimes Act. The minister has claimed, 'By clarifying the law in this area, we are not intending to expand the extent to which terminations occur, or restrict access to services.' Critics have claimed that if all the Bill is intending to do is to maintain the status quo with regard to access to abortion than it is not necessary.
No one has been prosecuted in Victoria under the ant-abortion Crimes Act provisions for 21 years. It is estimated that some 20,000 abortions are performed in Victoria annually and that one in three Victorian women have had an abortion at some point in their lives. Given the extent of the use of abortion and the lack of criminal prosecutions it has been claimed the Victoria's Abortion Law Reform Bill is simply not necessary. Indeed there are those who claim that when dealing with complex moral issues the law is simply too blunt an instrument and reformed or not we do not want our abortion practice determined by legislation.
Those who hold this view tend to argue that a society is better to have conservative legislation modified by more lenient judicial rulings and to have its practice shaped by medical practitioners actually responding to the circumstances of individual women. This is the situation that pertains in Victoria, where, as a famous pro-abortion campainger, Jo Wainer, has noted, 'The law has been ignored by the Federal government because Medicare refunds medical fees for abortion, by the State government because public hospitals provide abortion services and the Department of Human Services regulates the day procedure centres, and by medical colleges such as the Royal Australian and New Zealand College of Obstetricians and Gynaecologists because they have a policy on their web site supporting their members who provide this service.' Wainer argues that where a law is being ignored it should be abolished; others have argued that where it is ignored it does not need to be changed.

5. The Bill is more liberal than current arrangements and would normalise abortion
In Victoria, under current arrangements, a woman seeking an abortion has to have the support of her doctor that the procedure is necessary for her physical or psychological welbeing. Under the Abortion Law Reform Bill abortion would be available on request up to 24 months gestation. There are those who see this as a significant liberalisation and likely to lead to an increased number of abortions in this state.
Under the Abortion Reform Bill, any woman who wants an abortion during the first 24 weeks of pregnancy will be able to lawfully get one. Such abortions will be regulated 'like any other medical procedure', Women's Affairs Minister Maxine Morand, who is sponsoring the Bill, told Parliament. 'Abortion where the woman is 24 weeks pregnant or less will be a private decision for a woman in consultation with her medical practitioner,' she said. There are many who believe that this will almost certainly lead to an increase in the procedure.
It has been claimed that the law has symbolic value. According to this argument, to make something legal is to indicate that the society approves of those practices it makes legal. It has been claimed that this is a doubtful claim to make in relation to abortion which many appear to regard as an unfortunate necessity rather than an action they would enthusiastically endorse.
The concern has been expressed that explicitly making abortion legal may be an encourgaement to some women to undergo abortions, when, without this encouragement they might not.
David Palmer, in an article published in Online Opinion in August 2007 stated, 'The major problem with making abortion legal without qualification ... is that the general public, including the young, will begin to think of abortion - once considered morally wrong, or at the very least morally dubious - as morally right. Abortion is not morally right. Even the ancient Greeks recognised the value of the unborn so that Hippocrates bound all doctors in his oath against procuring an abortion.
One practical consequence of the change in emphasis associated with decriminalisation of abortion would be that it will become much harder for a woman to resist calls from her boyfriend, her husband or other family members to undergo an abortion.'
A similar position has been put by Victoria's catholic bishops in response to Victoria's Abortion Law Reform Bill. In an open pastoral letter the Catholic bishops of Victoria have stated, 'The Law is a great educator and if the Law approves something then people gradually accept a new understanding of what is right and what is
wrong. People begin to think: "Abortion is lawful now, so it's right."
Taking abortion out of the Crimes Act would undoubtedly be a victory for the pro-abortion forces. But moving the regulation of abortion from the Crimes Act to the Health Act would also give strength to the fallacy that abortion is just an ordinary medical procedure.'

Arguments in favour of making abortion legal in Victoria
1. The decision as to whether to have an abortion or not rightly rests with the woman
The abortion reform Bill allows women to decide whether they wish to have an abortion up to 24 weeks gestation without having to seek medical support for their decision on the basis of the possible physical or psychological harm continuing with the pregnancy might cause them.
This position has been clearly stated by Julian Burnside, QC, the president of Liberty Victoria, in explaining the view of the organisation he heads. Burnside has stated, 'Liberty Victoria's position on this issue starts from a number of basic premises. First, that women have the intellectual and moral capacity to make decisions about their own fertility.
Second, the right to reproductive freedom is implicit in international conventions, specifically in provisions which refer to the right to privacy, health and equality. In particular, Article 16 of the Convention on the Elimination of Discrimination Against Women (CEDAW) requires all States Parties to take appropriate measures to eliminate discrimination against women in all matters relating to marriage and family relations. It requires Parties to ensure, on a basis of equality of men and women "the same rights to decide freely and responsibly on the number and spacing of their children and to have access to the information, education and means to enable them to exercise these rights". Australia is a party to CEDAW. Australian law should be brought into conformity with its international human rights obligations.'
From this point of view the decision as to whether to proceed with a pregnancy or not can only be made by the woman. The Victorian Bill largely supports this right; however, there are those who have criticised the Bill because it requires that apregnant woman acquire the support of two doctors if she wishes to terminate a pregnancy after 24 weeks.

2. Legalising abortion would formalise what already occurs in this state
Abortion has been part of the Crimes Act since 1958 and can carry a penalty of 10 years' jail. However, in 1969 Justice Clifford Menhennitt ruled in the Supreme Court, in a case brought against Melbourne gynaecologist Ken Davidson, that abortion could be legal if it were necessary 'to preserve the  woman from a serious danger to her life or her physical or mental health'.
As a result of the Menhennitt ruling, no one has been charged in relation to abortion in Victoria for 21 years. It is estimated that there are some 20,000 terminations each year in this state. That is the equivalent of about 55 abortions a day. The section of the Crimes Act prohibiting abortion is therefore effectively defunct.
Supporters of the Victorian Government's Abortion Bill argue that all they are attempting to do is bring the statute into line with reality. That is, the Menhennitt ruling has meant that abortion is no longer treated as a crime in Victoria; therefore, it should no longer be listed as a crime under the Victorian Crimes Act.
Abortion rights campaigner, Jo Wainer, has stated, 'The law has been
ignored by the Federal government because Medicare refunds medical fees for abortion, by the State government because public hospitals provide abortion services and the Department of Human Services regulates the day procedure centres, and by medical colleges such as the Royal Australian and New Zealand College of Obstetricians and Gynaecologists because they have a policy on their web site supporting their members who provide this service. This anomaly is making the law an ass. It is a hangover from ancient thinking. Let us just dig it out and turf it away. We don't need this.'

3. Legalising abortion would largely remove the risk of prosecution that still exists for those who procure or perform abortions
It has been claimed that while abortion remains technically a crime in Victoria doctors who perform the procedure cannot be certain that they will not face prosecution.
Julian Burnside, QC, the president of Liberty Victoria, has stated, 'The law must be clear and certain. Australian abortion law has been described by medical practitioners as inadequate, "unclear and outdated"... They argue that the "current laws have grey areas that leave doctors vulnerable to accusations, negative publicity and career damage".
Furthermore, by maintaining the abortion provisions in the Crimes Act 1958, the threat of criminal conviction hangs over the heads of doctors, women and their partners should they terminate the women's pregnancy. It is time for politicians to clarify the law and correct this untenable position.'
The same position has been put by abortion rights campaigner, Jo Wainer, who has stated, 'This law, which has to go, criminalises twenty thousand women a year, it threatens doctors and nurses and other providers with ten years imprisonment. All the other people who take part, like the pharmaceutical and medical supply companies, nursing and counselling staff, receptionists and security guards, are liable for five years in jail.'
The legal restrictions surrounding late term abortion are even less clear. Lachlan J de Crespigny and Julian Savulescu, in an article published in The Medical Journal of Australia have noted, 'Legal uncertainty about abortion is further increased by the crime of child destruction (this crime applies only to abortions performed late in pregnancy). Victoria, Queensland, South Australia and the Northern Territory have child destruction laws. The situations in which the law applies are variable and uncertain.
In Victoria, abortion in late pregnancy is said to be lawful if done in good faith, solely to preserve the mother's life.2 Courts may interpret lawful grounds for termination to include situations in which there is a serious risk to the pregnant woman's life or health, but we cannot be certain.
This leaves two differing laws on abortion that might apply in a particular case, despite the fact that the House of Lords debate on the Infant Life (Preservation) Act 1929 (which created the new offence of child destruction) made it clear that it was not introduced as a second, potentially conflicting law of abortion. Its purpose was to cover the time during and immediately after labour until the cutting of the umbilical cord, a previously unlegislated period - too late for the law on abortion, but too early for the law on infanticide.'

4. The Abortion Law Reform Bill recognises the special status of late-term pregnancies
It has been noted that the Abortion Law Reform Bill makes specific allowance for the special circumstances that surround late-term abortion. Late-term abortion poses a particular set of problems.
Firstly, there is the issue of viability. A baby born after 24 weeks is, with special assistance, capable of survival. The further through the gestation period an abortion is performed, the more likely it is that were the pregnancy terminated with a delivery rather than an abortion, the baby/foetus would survive.
Secondly, there are the related issues of sensitivity to pain and the development of consciousness. Thoughout most of the debate surrounding this Bill the question of whether abortion should occur has not been the issue. What is being discussed are the circumstances under which it will occur. Where late-term abortion is being considered there is less certainty in the public mind and that of legislators.
This is in part because the more developed a foetus is the more likely it is to be able to feel pain and question of cruelty as well as that of right to life comes into play. There is also the issue of personhood. The nearer a foetus is to full term, the more possible it is to see it as a person in its own right and thus the more problematic ending its life seems.
One of the Law Reform Commission's options for dealing with abortion law reform in Victoria was to make abortion available on request to full term. The Bill has not taken up this option. Instead it has adopted another option suggested by the Commission which is that abortion be available on request up to 24 weeks and that after that point it requires the agreement of two doctors that an abortion is necessary for the woman's welbeing before that abortion can proceed. This has been interpreted as an attempt to recognise the special status of late-term pregnancies.

5. A majority of Australians support the legalisation of abortion
Though survey results clearly vary according to exactly what questions are asked (and, in particular, how detailed the questions are) most survey results have revealed widespread support for making abortion readily available to Australian women.
The 2004 Australian Election Study (AES) reveals that over 50% of respondents believe a woman should be able to readily access "abortion on demand."
When including r e s p o n d e n t s who believe that abortion should be allowed under special circumstances, support for abortion increases to almost 90%.
In contrast, only 4% felt that 'abortion should not be allowed under any circumstances.'
Similarly, the Public Health Association of Australia has stated, 'It is overwhelmingly
clear that the majority of Australians support liberal access to abortion.'
According to the 2003 Australian Survey of Social Attitudes (AuSSA) 81.2% of
respondents were prochoice, agreeing that a 'women should have the right to choose
whether or not she has an abortion'.
Only 9.4% of those surveyed disagreed that a woman should have the right to choose, with only 4.4% disagreeing strongly with the statement.
Poll findings such as these have repeatedly been used to justify calls for the liberalising or decriminalising of women's access to abortion.

Further implcations
It remains to be seen whether the Abortion Law Reform Bill 2008 will pass through the Victorian Legislative Council and become law. Were it to do so it is possible that it will increase the number of abortions performed in Victoria. This may in part be a result of women from other states, with less liberal abortion laws, coming to Victoria to have an abortion performed. There is currently nothing in the Victorian legislation that would prevent this from happening.
Many women are regarding this Bill as a victory as it removes abortion, up to 24 weeks, from the Crimes Act. The choice now rests exclusively in the hands of the woman concerned, without her having to offer any justification to a medical practitioner.
There are, however, those who see this very freedom of access as cause for concern. Those who see abortion as at best the least undesirable of a set of undesirable options argue that women need more supprt than is currently being supplied. Abortion, they argue, is not a solution, it is the acknowledgement of a problem.
That Victoria has an average of 20,000 abortions a year is seen by some as indicating a massive failure of contraception and a disconcerting indicator that many women are having intercourse either unwillingly or with an element of coercion. It may also suggest a lack of access to contraception, a failure to recognise its importance or the effects of alcohol.
This number of abortions is also seen as indicating that for many women there are not sufficient social supports to make pregnancy a desirable option for them. This includes a wide-spread lack of maternity leave and inadequate provision of affordable childcare.

Newspaper items used in the production of this issue outline

The Age:  August 21, page 17, comment by Paul Austin, `The risks in abortion reform'.
http://www.theage.com.au/opinion/the-risks-in-abortion-reform-20080820-3yw1.html?page=-1

The Age:  August 20, page 12, letters (on Colleen Hartland MP) incl, `Taking the easy way out will not make you happy / Bravo, for a secret shared'.
http://www.theage.com.au/opinion/letters/taking-the-easy-way-out-will-not-make-you-happy-20080819-3y8f.html

The Herald-Sun:    August 19, page 19, comment by Mirko Bagaric, `Pleas for living from the unborn'.
http://www.news.com.au/heraldsun/story/0,21985,24201643-5000117,00.html

The Age:  August 15, page 13, comment by Nicholas Tonti-Filippini, `Support when it really counts'.
http://www.theage.com.au/opinion/support-when-it-really-counts-20080814-3vnj.html

The Age:  August 15, page 13, comment by Roger Short, Lachlan De Crespigny, Julian Savalescu, `Giving women total control'.
http://www.theage.com.au/opinion/giving-women-total-control-20080814-3vnk.html

The Age:  August 28, page 19, analysis  (on MPS and the "conscience vote") by Paul Austin, `MPs shine in the absence of the party line'.
http://www.theage.com.au/opinion/mps-shine-in-the-absence-of-the-party-line-20080827-43yh.html

The Herald-Sun:    August 25, page 23, comment by Jill Singer, `The anguish of a female choice'.
http://www.news.com.au/heraldsun/story/0,21985,24233499-5000117,00.html

The Australian:   August 25, page 15, analysis by Caroline Overington, `Women with the law on their side'.
http://www.theaustralian.news.com.au/story/0,,24233593-28737,00.html?from=public_rss

The Age:  August 24, page 18, editorial, `New law will not end abortion controversy'.
http://www.theage.com.au/opinion/editorial/new-law-will-not-end-abortion-controversy-20080823-40u4.html?page=-1

The Herald-Sun:    August 22, page 36, comment by Maxine Morand, `Legal reality for female choice'.
http://www.news.com.au/heraldsun/story/0,21985,24220519-5000117,00.html

The Age:  August 22, page 13, comment by Leslie Cannold, `Men show moral arrogance in wanting control of abortion'.
http://www.theage.com.au/opinion/men-show-moral-arrogance-in-wanting-control-of-abortion-20080821-3zka.html

The Age:  September 11, page 14, editorial, `Abortion: removing the shadow of criminality'.
http://www.theage.com.au/opinion/editorial/abortion-removing-the-shadow-of-criminality-20080910-4dse.html

The Australian:   September 6, page 24, comment by Angela Shanahan, `Abortion has a new adversary'.
http://www.theaustralian.news.com.au/story/0,25197,24301603-5006785,00.html

The Age:  September 6, Insight section, page 4, comment by Gideon Haigh, `Abortion: the way we were'.
http://www.theage.com.au/national/abortion-the-way-we-were-20080905-4aq7.html

The Australian:   September 5, page 6, news item by Rick Wallace, `Pro-choice lobby fires electoral armoury'.
http://www.theaustralian.news.com.au/story/0,25197,24295327-5006785,00.html

The Age:  September 12, page 15, comment by Ray Cassin, `Exercising the right to choose is not just the prerogative of one group'.
http://www.theage.com.au/articles/2008/09/11/1220857738131.html