Proposed amendments to the Act have been put on the website of the Ministry of Health and Family Welfare for comments/suggestions by stakeholders and the public. www.mohfw.nic.in The proposed amendments include allowing registered ayurvedic doctors, homeopaths, nurses, ANMs to carry out abortions. Also, any woman can get an abortion on demand till 12 weeks and thereafter till 24 weeks under certain conditions. The effect of these amendments will have a deleterious effect on the reproductive health of women as clinics will spring up in rural and semi-rural areas with few checks for hygiene and quality of services provided. Such clinics will thrive on sex selective abortions which will be detrimental to the social fabric of the country. Time has been given till 10 November to submit comments. This is inadequate. I have submitted my comments which I am pasting below. Should IAC take a view? In any case individuals can submit comments to saurabh.mittal89@nic.in Pavan Nair.
Dear Shri Mittal,
Please refer to the notice on the website of the Ministry of Health and Family Welfare regarding the above. I am submitting my para wise comments and suggestions to the proposed amendments as under. At the outset, however, let me make it clear that these amendments will have a deleterious effect on the reproductive health of women and will encourage the practice of female foeticide. The proposal to extend the date for termination to 24 weeks seems reasonable. The time given for submission of comments is inadequate and the amendments need much wider dissemination for discussion and debate. The purpose of these amendments seems to encourage the use of abortion to restrict births and encourage family planning. This is dangerous and problematic as a policy when cheap and easily available contraceptives can be widely distributed. Contraceptive failure is very rare. Nearly 80% of abortions being done in Delhi are for this reason. I have obtained this information under RTI from your Ministry.
Para 2. The concept of using 'health care providers' ( registered and trained ayurvedic doctors, homeopaths, nurses, ANMs etc) will encourage abortion clinics being established in rural and semi rural areas. To check facilities provided and conditions of hygiene will be near impossible. Not having a gynecologist or a surgeon present will lead to complications.
Para 4 (II). Substituted Para 2a. This implies that abortion should be made available on demand till 12 weeks. In a country like India, we have not been able to make birthing facilities available, how will it be possible for the government to make facilities for abortion available in rural areas? Obviously private practitioners will fill that gap. Secondly, sex determination becomes feasible at about the same time. This Section will be misused to carry out sex selective abortions even till 15 weeks. Who will establish how far the pregnancy has gone. The health care provider.
Explanation (ii) is redundant since the pregnant woman can seek abortion under the Para 2a above. In any case there should be a clause for married couples where abortion should be made available only if they have two or more surviving or adopted children. These amendments will allow a married couple to terminate even first healthy pregnancies on grounds of contraceptive failure after 12 weeks and on no particular ground before.
I am copying this mail to the Minister and a few others who may be interested. Please acknowledge receipt of this mail. Col Pavan Nair VSM (Retd)
