Author: Ayşe Esra Kara, LLM in European Union Law at Dokuz Eylül University, 2021- ongoing, email: [email protected]
Editor: Tofig Shahniyarov, MPA at ADA University, 2020-2022, Doctor of Philosophy – PhD at Middlesex University, e-mail: [email protected]
Abstract
In international law, it is possible to find many regulations regarding the protection of human rights. While such regulations clearly recognize some human rights, others are not explicitly defined as human rights, but they are under the umbrella of other rights. Access to abortion is in the second group. Although access to abortion is associated with several rights such as the right to life, the right to health, the right to be free from discrimination, the right to be free from torture or cruel, inhuman or degrading treatment or punishment and the right to privacy, it has become more restricted now than before due to a recent ruling of Constitutional Tribunal of Poland. As a result, it has led to an increase in human rights violations. Arguably, this decision undermines the core values of the European Union which require its member states to respect its core values.
Keywords: Poland, European Union, Abortion, Human Rights, Sexual and Productive Health Rights, Women Rights, ECtHR.
Introduction
The recent change with regard to abortion in Polish law received reactions from all over the world, especially from the Polish people. Those people who objected to that amendment claimed that the amendment violates the human rights of women.
In this article, I will evaluate this issue within the framework of the European Union law. First of all, I am going to discuss the violations of human rights that occur due to the restriction of access to abortion. In the following section, I will examine the legislation on abortion in Poland and the changes made. Finally, in light of all this, I will evaluate restrictions on access to abortion in Poland within the framework of the European Union law.
- Status of abortion in international human rights law
Although sources of international law do not often define access to abortion as a human right, it is associated with other fundamental rights in many international documents. Therefore, in this section, I will discuss the relationship between these rights and abortion.
One of the rights that is worthy of mentioning is the right to health. At the International Conference on Population and Development convened in 1994, the states accepted the Program of Action, which presented the concepts of sexual and reproductive health and reproductive rights.[1] The Program of Action emphasizes that unsafe abortion is a serious public health concern.[2]
According to the World Health Organization (WHO), “Unsafe abortion occurs when a pregnancy is terminated either by persons lacking the necessary skills or in an environment that does not conform to minimal medical standards or both.” Moreover, the WHO indicated the existing obstacles to accessing safe abortion. Accordingly, restrictive legislation of the states, poor access to services, expensive prices, stigma, conscientious objection by healthcare providers, and some unnecessary requirements make it difficult for women to have healthy access to abortion.[3]
In line with the documents mentioned above, restriction of access to abortion in various ways pushes women towards unsafe abortion, which in turn threatens the health of women.
It is necessary to emphasize the right to life as the WHO noted that nearly all deaths from unsafe abortion occur in countries where access to abortion is severely restricted.[4]
According to the Human Rights Committee, which is one of the United Nations Treaty Bodies, state parties may impose some measures for optional abortion, but these measures must not violate the right to life of the pregnant person. If there is a risk to the life or health of the pregnant person, or if maintaining the pregnancy will cause the pregnant person significant pain or suffering, states parties must ensure that the pregnant person has access to safe, legal, and effective abortion. States parties may not go against their duty to ensure that women and girls do not have to undertake unsafe abortions in their pregnancy and abortion regulations and review their abortion laws accordingly. For example, women and girls who resort to abortion should not be punished because it will push them towards unsafe abortion methods.[5]
Since the restriction of access to abortion also concerns the pregnant person’s body, it is essential to examine the right to privacy as well. According to the report of the Working Group on the issue of discrimination against women in law and in practice, the right of women and girls to decide about their own bodies and reproductive functions is at the centre of their right to equality and privacy. In addition, this right includes the private matters of the physical and psychological integrity of the person and is necessary for the exercise of other rights.[6] Also, while examining this issue, it is useful to mention the Tysiąc v Poland[7] decision of the European Court of Human Rights (ECtHR). In the case, the applicant, who was pregnant with her third child, went for a check-up because she was worried about the risk of it causing a health problem. Three different ophthalmologists examined her and said that the pregnancy and delivery constituted a risk to her eyesight. Despite the applicant’s requests, none of the doctors issued a certificate for termination of pregnancy as there was no certainty. Later, a general practitioner examined the applicant and prepared a certificate stating that this pregnancy put her health at risk. The applicant made an appointment with a gynaecologist, knowing that, according to the laws of that time, she could terminate the pregnancy with that certificate. However, when the applicant visited a gynaecologist, the gynaecologist did not allow the applicant to have an abortion. Shortly after the birth, the applicant’s eyesight began to deteriorate. Finally, the applicant learned that she would need continued care and assistance. The ECtHR referred to the deterrence of abortion being a crime in Poland at that time and the lack of transparent and clear procedures to demonstrate compliance with legal conditions for abortion. The Court noted that, as the punishment for terminating a pregnancy is a deterrent for doctors, the provisions allowing the abortion should alleviate this deterrent effect on the doctors. Due to these deficiencies of Polish law on abortion, the ECtHR held that Poland had not complied with its positive obligations as it had not taken adequate measures to prevent the violation of the applicant’s right to private life.
The Committee on the Elimination of Discrimination against Women has evaluated violations of women’s sexual and reproductive health and rights as gender-based violence and even stated that these violations can sometimes constitute torture or cruel, inhuman, or degrading treatment. According to the Committee, “…forced sterilizations, forced abortion, forced pregnancy, criminalisation of abortion, denial or delay of safe abortion and post-abortion care, a forced continuation of pregnancy, abuse and mistreatment of women and girls seeking sexual and reproductive health information, goods and services” are examples of these violations.[8] In addition, one of the rulings of the ECtHR, R.R. v Poland[9] is extremely important for this issue. The applicant, who was 18 months pregnant, learned from the ultrasound that the foetus was suffering from some malformation. Although the applicant requested a referral for genetic examination from different doctors, again and again, the doctors refused her request. When she finally got the test and the results, she learned that the legal abortion period had passed. ECtHR examined this case under Articles 3 and 8 of ECHR. Accordingly, the applicant’s vulnerable situation was known but not taken seriously; although it was quite normal for the applicant to want to know about the health of the fetus and the options available to her, she had to endure this uncertainty as the doctors procrastinated her for a long time. The Court described this attitude as degrading treatment. ECtHR also stated that the applicant was not able to timely access the medical services that provide information on the foetus’ health. The Court considered the right to access such information as a part of the right to private life. Accordingly, in countries where women can have an abortion under certain conditions, effective access to information on the health of the mother and the foetus is directly linked to the exercise of personal autonomy. The Court stated the obligation of Poland to provide relevant, full and reliable information on the health of the foetus to pregnant women, as in the “Tysiąc v. Poland” case. As a result, the Court held that Poland did not have an effective mechanism to guarantee the applicant’s right to access to abortion and that Poland had violated the right to privacy by failing to fulfil its positive obligation.
Finally, it is necessary to mention the link between abortion and the right to be free from discrimination. The Committee on the Elimination of Discrimination against Women considered that the measures are taken to eliminate discrimination against women insufficient if there are problems in the health system regarding the treatment of illnesses specific to women. Also, it noted that the refusal of a state party to provide certain reproductive health services for women is a discriminatory attitude.[10]The Committee stated the criminalization of acts that only women can do, such as abortion, is a discriminatory attitude against women.[11] The Committee indicated that women are punished disproportionately because of their status or situation, such as having an abortion.[12] It also stated that criminal regulation of abortion violates women’s equal status and constitutes discrimination, as well as restricting women’s privacy, self-determination, and autonomous decision-making. In addition, these punishments have a stigmatizing effect on women.[13]
- Legislation on abortion in Poland
The difficulty of access to abortion in Poland emerged with the “Act on Family Planning, Protection of Human Fetus, and Conditions for Permissibility of Abortion”, also called anti-abortion law.[14] The original version of this law was allowing abortion in only three cases:
1- If pregnancy endangers the life of the woman;
2- If the prenatal control indicates severe and irreversible damage to the embryo;
3- If an illegal act such as incest or rape caused this pregnancy.
The first and second situations had to be approved by two doctors other than the doctor involved in the case; the third situation had to be determined by a legal prosecution.[15] For a short period, women were able to have abortions due to their personal and financial problems with the amending act in 1996, however, in 1997 Constitutional Tribunal considered it unconstitutional to terminate the pregnancy because of the personal and financial problems of women.[16]
On 22 October 2020, the Constitutional Tribunal ruled that Article 4a(1)2 in abortion law allowing women to have abortions when there is a high risk of foetal impairment is unconstitutional.[17] In this decision, the Constitutional Tribunal relied on Articles 30, 31 and 38 of the Constitution, which protect human life, personal dignity, and freedom. It was implicitly stated in the decision that the unborn human embryo or foetus should be seen as equal to humans in terms of rights and freedoms.[18] Since 27 January 2021, the new abortion law of Poland has been implemented in the country. According to this law, women are not able to have an abortion even if there is a high possibility of the foetus has a severe and irreversible defect or incurable illness. In other words, today women living in Poland can terminate their pregnancy only if the pregnancy endangers their lives or the pregnancy occurred because of a crime.[19]
- Evaluation of the restriction of access to abortion in Poland within the framework of the European Union law
The European Union is founded on certain values related to human rights. The European Union (EU) emphasized it both in the founding treaties and in the European Union Charter of Fundamental Rights. As a member of the EU, this also concerns Poland which has undertaken to respect the EU’s core values. Therefore, it is necessary to discuss whether the amendment on abortion in Poland violates human rights and complies with EU law.
Firstly, it is necessary to mention Article 2 of the Treaty on the European Union (TEU). According to this article:
“The Union is founded on the values of respect for human dignity, freedom, democracy, equality, the rule of law and respect for human rights, including the rights of persons belonging to minorities. These values are common to the Member States in a society in which pluralism, non-discrimination, tolerance, justice, solidarity and equality between women and men prevail[20]“.
Another crucial provision is Article 7 of the TEU as it explains what to do if one of the member states violates one of these values. Accordingly, if the European Council determines duly that one of the member states has violated Article 2 severely and consistently, the Council may decide to suspend some of these rights derived from the founding treaties of this member state.
Furthermore, it is worth remembering the link between the EU and the European Convention for the Protection of Human Rights and Fundamental Freedoms (ECHR). According to Article 6 (3) of the TEU, “Fundamental rights, as guaranteed by the European Convention for the Protection of Human Rights and Fundamental Freedoms and as they result from the constitutional traditions common to the Member States, shall constitute general principles of the Union’s law”.
As the TEU has included the rights protected by the ECHR in EU legislation with this article; if one of the member states violates any of the rights protected in the ECHR, it will also mean that it violates the EU law.
Another document that protects fundamental rights is the Charter of Fundamental Rights of the European Union. The TEU equated this Charter with the founding treaties and recognized the rights, freedoms and principles contained in it.[21] The benefit of this Charter is that it reaffirms and makes more visible the rights, freedoms and principles already existing in the founding treaties of the EU. However, it does not create new rights or principles.[22]
It is necessary to evaluate the restrictions on access to abortion in Poland in light of the provisions above. The Resolution[23] prepared by the European Parliament for the first anniversary of the de facto abortion ban in Poland will shed light on this issue. In this text, the EU condemned the Polish Constitutional Tribunal’s ruling restricting access to abortion and this attack on sexual and reproductive health and rights. EU urged the Polish Government to provide safe, legal, free, high-quality, and accessible abortion services to women and girls. It underlined the right of women to life, health and equality; and their freedom from discrimination, violence and torture or cruel, inhuman and degrading treatment, and asked Poland to respect, carry out and support these rights.[24]
According to the Resolution, despite many protests against the restriction of abortion in Poland, the ruling was officially published, increasing the prevalence of unsafe abortion, and forcing women to have abortions in other countries. This is not only a sabotage to women’s health and rights, their sexual and bodily autonomy and integrity but also a risk to their lives.[25]In the first 12 months after this law came into force, 34000 people from Poland received help from Abortion Without Borders to have an abortion.[26]
Due to this ruling, the prevalence of the stigma on sexual and reproductive human rights is increasing. Also, women who cannot afford a medical abortion or abortions abroad, and women who do not have access to information technologies are affected disproportionately.[27] Because of the fear of litigation, abortion services are provided only in a few hospitals. Women frequently avoid using their services out of fear of cumbersome, deliberately delayed procedures and referrals. There are women in Poland who suffer from serious mental health problems due to the lack of government support to access legal abortion services. The number of women seeking legal abortion for mental health reasons is increasing.[28] These restrictions do not reduce the demand for abortions, but they cause women to have unsafe abortions, travel to different countries for abortions, or maintain unwanted pregnancies.[29]
Doctors in Poland do not want to be associated with abortion services because of the law, social stigma, fear, and pressure. There are also some doctors who create non-statutory barriers or who make it harder for women to access their rights to prenatal tests and information. However, it is unacceptable to violate a patient’s right to fully benefit from the healthcare services provided by law because of another person’s personal beliefs about abortion.[30]
The legal regulations restricting access to abortion which push women to have an unsafe abortion are highly deemed discriminatory as they create obstacles to a health service that only women can benefit from. Since Polish law does not provide them with safe abortion services, women have to risk their health and lives by having unsafe abortions. They do not choose to have unsafe abortions; current circumstances force them to have them. It is not surprising that women feel insecure and depressed because their very fundamental right such as the right to life is under threat.
Moreover, these restrictions seriously interfere with women’s decisions about their bodies and lives. Pregnancy has several impacts on the lives of women such as hormonal changes, gaining weight, etc. However, the impacts are not just about the pregnancy period. A woman, who is forced to maintain pregnancy, will have to change her entire life after the birth. It is a crucial decision to make, therefore the only person who makes a decision about a woman’s body should be the owner of that body. This amendment, which interferes with the decisions of women about their own bodies, violates the private life of them. Such incidents were occurring even before when access to abortion was less restricted in Poland. In R.R. v Poland, although the applicant had a legal right to have an abortion, she could not access the abortion service due to the opposite opinions of doctors. As a result, a decision that had to be made by the applicant was interfered with. Although the law at the time of the incident was more flexible than it is now, such kind of problems was still occurring. As the current law has a more restrictive attitude against abortion, the prevalence of such incidents will probably increase.
Last but not least, such restrictive laws provide grounds for degrading treatment, as in the case of R.R. v Poland. As stated in the report of the European Parliament, doctors avoid providing abortion services for a number of reasons. Fear of punishment or having anti-abortion views are a few examples of these reasons. Such attitudes of doctors can cause women to have difficult times in a process where they are already vulnerable because of the pregnancy. Some of the women have to fight for rights that would normally be easily accessible, which is frustrating for them both physically and psychologically.
Conclusion
Access to abortion in Poland was already difficult before the Constitutional Tribunal decision. In fact, it is possible to see the human rights violations caused by the limited access to abortion in some rulings of the ECtHR. According to the Committee of Ministers of the Council of Europe, Poland has not implemented the decisions of ECtHR regarding access to abortion for over 13 years.[31]
Respect for human rights is one of the EU’s values. EU legislation has protected human rights and expected member states to respect them. As a member of the EU, Poland should also respect these rights. However, the amendment made in Poland attacks women’s human rights such as the right to life, right to health, right to be free from discrimination, right to be free from torture or cruel, inhuman or degrading treatment or punishment and right to privacy. Instead of taking measures to prevent these human rights violations, Poland follows a policy that will increase these human rights violations by making women’s access to abortion difficult. In this case, it is not possible to say that recent restrictions on access to abortion in Poland comply with EU law.
Bibliography
Abortion Support Network, Abortion Without Borders helps more than 34,000 people in Poland access abortions, (2021), https://www.asn.org.uk/abortion-without-borders-helps-more-than-34000-people-in-poland-access-abortions/
Aleksandra Siwek, Abortion in Poland. Between politics, ethics and religion, KFUG, (2022).
Committee on the Elimination of Discrimination against Women, General recommendation No. 35 on gender-based violence against women, updating general recommendation No. 19, paragraph 18, (2017), https://docstore.ohchr.org/SelfServices/FilesHandler.ashx?enc=6QkG1d%2fPPRiCAqhKb7yhsldCrOlUTvLRFDjh6%2fx1pWAeqJn4T68N1uqnZjLbtFua2OBKh3UEqlB%2fCyQIg86A6bUD6S2nt0Ii%2bndbh67tt1%2bO99yEEGWYpmnzM8vDxmwt .
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Committee on the Elimination of Discrimination against Women, General recommendation No. 33 on women’s access to justice, Paragraph 47/b, (2015), https://digitallibrary.un.org/record/807253
Committee on the Elimination of Discrimination against Women, Report of the inquiry concerning the United Kingdom of Great Britain and Northern Ireland under article 8 of the Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women, Paragraph 59, (2018), https://tbinternet.ohchr.org/Treaties/CEDAW/Shared%20Documents/GBR/INT_CEDAW_ITB_GBR_8637_E.pdf
Dominic Standish, From Abortion on Demand to its Criminalization: the Case of Poland in the 1990s, Lee, E. (eds) Abortion Law and Politics Today, P. Macmillan, pp. 116-129 (1998)
Dominika Tykwińska-Rutkowska, The right to abortion in Poland in the light of the Constitutional Tribunal’s judgment of 22 October 2020, 29 S. I. Toruniensia, pp. 419-440 (2021)
Emil Filtenborg and Stefan Weichert, Battle lines drawn: The two sides of Poland’s abortion divide, (2022), https://www.euronews.com/2022/01/27/battle-lines-drawn-the-two-sides-of-poland-s-abortion-divide
European Parliament, European Parliament resolution of 11 November 2021 on the first anniversary of the de facto abortion ban in Poland, (2021), https://www.europarl.europa.eu/doceo/document/TA-9-2021-0455_EN.html
Fredrikke Hornfelt Andersen, Impacts of a Strict Abortion Law on Young Polish Women; an Integral Approach, UIB, (2022).
Human Rights Committee, General comment No. 36, Article 8, (2019), https://documents-dds-ny.un.org/doc/UNDOC/GEN/G19/261/15/PDF/G1926115.pdf?OpenElement
Human Rights Council, Report of the Working Group on the issue of discrimination against women in law and in practice, Paragraph 35, (2018), https://www.ohchr.org/sites/default/files/Documents/Issues/Women/WG/A_HRC_38_46_EN.pdf
International Conference on Population and Development (ICPD), Conference on Population and Development, (1994), https://www.unfpa.org/events/international-conference-population-and-development-icpd.
Martha Bulchoc, Abortion Law and Human Rights in Poland: The Closing of the Jurisprudential Horizon, 14 Hague J. R. L., pp. 73-99, (2022).
Programme of Action of the International Conference on Population and Development, article 8 (25), 1994, https://www.un.org/en/development/desa/population/migration/generalassembly/docs/globalcompact/A_CONF.171_13.pdf
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Cases
Case of R.R. v Poland, Application no. 27617/04, (ECtHR. 2011), https://hudoc.echr.coe.int/fre?i=001-104911 .
Case of Tysiąc v Poland, Application no. 5410/03, (ECtHR. 2007), https://hudoc.echr.coe.int/eng?i=001-79812
Treaties
Charter of Fundamental Rights of the European Union, European Union, (2012), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12012P/TXT
Consolidated version of the Treaty on European Union, European Union, (2012), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A12012M%2FTXT.
[1] International Conference on Population and Development (ICPD), Conference on Population and Development, (1994), https://www.unfpa.org/events/international-conference-population-and-development-icpd.
[2] Programme of Action of the International Conference on Population and Development, article 8 (25), 1994, https://www.un.org/en/development/desa/population/migration/generalassembly/docs/globalcompact/A_CONF.171_13.pdf .
[3] World Health Organisation, Preventing Unsafe Abortion, p. 2, (2019), https://apps.who.int/iris/bitstream/handle/10665/329887/WHO-RHR-19.21-eng.pdf .
[4] World Health Organisation, Safe abortion: Technical & policy guidance for health systems, p. 1, (2015), https://apps.who.int/iris/bitstream/handle/10665/173586/WHO_RHR_15.04_eng.pdf .
[5] Human Rights Committee, General comment No. 36, Article 8, (2019), https://documents-dds-ny.un.org/doc/UNDOC/GEN/G19/261/15/PDF/G1926115.pdf?OpenElement .
[6] Human Rights Council, Report of the Working Group on the issue of discrimination
against women in law and in practice, Paragraph 35, (2018), https://www.ohchr.org/sites/default/files/Documents/Issues/Women/WG/A_HRC_38_46_EN.pdf .
[7] Case of Tysiąc v Poland, Application no. 5410/03, (ECtHR. 2007), https://hudoc.echr.coe.int/eng?i=001-79812 .
[8] Committee on the Elimination of Discrimination against Women, General recommendation No. 35 on gender-based violence against women, updating general recommendation No. 19, paragraph 18, (2017), https://docstore.ohchr.org/SelfServices/FilesHandler.ashx?enc=6QkG1d%2fPPRiCAqhKb7yhsldCrOlUTvLRFDjh6%2fx1pWAeqJn4T68N1uqnZjLbtFua2OBKh3UEqlB%2fCyQIg86A6bUD6S2nt0Ii%2bndbh67tt1%2bO99yEEGWYpmnzM8vDxmwt .
[9] Case of R.R. v Poland, Application no. 27617/04, (ECtHR. 2011), https://hudoc.echr.coe.int/fre?i=001-104911 .
[10] Committee on the Elimination of Discrimination against Women, General recommendation No. 24: Article 12 of the Convention (women and health), Paragraph 11, (1999), https://tbinternet.ohchr.org/Treaties/CEDAW/Shared%20Documents/1_Global/INT_CEDAW_GEC_4738_E.pdf .
[11] Committee on the Elimination of Discrimination against Women, General recommendation No. 33 on women’s access to justice, Paragraph 47/b, (2015), https://digitallibrary.un.org/record/807253 .
[12] Committee on the Elimination of Discrimination against Women, General recommendation No. 33 on women’s access to justice, Paragraph 49, (2015), https://digitallibrary.un.org/record/807253 .
[13] Committee on the Elimination of Discrimination against Women, Report of the inquiry concerning the United Kingdom of Great Britain and Northern Ireland under article 8 of the Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women, Paragraph 59, (2018), https://tbinternet.ohchr.org/Treaties/CEDAW/Shared%20Documents/GBR/INT_CEDAW_ITB_GBR_8637_E.pdf
[14] Dominika Tykwińska-Rutkowska, The right to abortion in Poland in the light of the Constitutional Tribunal’s judgment of 22 October 2020, 29 S. I. Toruniensia, 419, 419, (2021).
[15] Dominic Standish, From Abortion on Demand to its Criminalization: the Case of Poland in the 1990s, Lee, E. (eds) Abortion Law and Politics Today, P. Macmillan, 116, 118, (1998).
[16] Tykwińska-Rutkowska, p. 420; Fredrikke Hornfelt Andersen, Impacts of a Strict Abortion Law on Young Polish Women; an Integral Approach, UIB, p.2 (2022).
[17] Martha Bulchoc, Abortion Law and Human Rights in Poland: The Closing of the Jurisprudential Horizon, 14 Hague J. R. L., 73, 86, (2022).
[18] Aleksandra Siwek, Abortion in Poland. Between politics, ethics and religion, Universität Graz, p. 29, 2022.
[19] Emil Filtenborg and Stefan Weichert, Battle lines drawn: The two sides of Poland’s abortion divide, (2022), https://www.euronews.com/2022/01/27/battle-lines-drawn-the-two-sides-of-poland-s-abortion-divide .
[20] Consolidated version of the Treaty on European Union, European Union, (2012), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A12012M%2FTXT .
[21] TEU, article 6(1).
[22] Charter of Fundamental Rights of the European Union, European Union, (2012), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12012P/TXT.
[23] European Parliament, European Parliament resolution of 11 November 2021 on the first anniversary of the de facto abortion ban in Poland, (2021), https://www.europarl.europa.eu/doceo/document/TA-9-2021-0455_EN.html .
[24] Resolution, p. 8, paragraph 1.
[25] Resolution, p. 5, paragraph I.
[26] Abortion Support Network, Abortion Without Borders helps more than 34,000 people in Poland access abortions, (2021), https://www.asn.org.uk/abortion-without-borders-helps-more-than-34000-people-in-poland-access-abortions/ .
[27] Resolution, p. 6, paragraph M.
[28] Resolution, p. 6, paragraph N.
[29] Resolution, p. 8, paragraph 4.
[30] Resolution, p. 6, paragraph P.
[31] Resolution, Paragraph F.
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