Table 2 Religious edicts, Islamic law and practice of TOP in Islamic countries

Edict/Law

Edict*

Edict

Edict

Law

Law

Common law/edicts/Clandestine practices

When TOP permissible?

Rape victims severe foetal anomaly (SFA)

SFA

SFA

SFA developmental delay

SFA intrauterine death risk to mother

SFA/Rape/Social/economic conditions

Rules for TOP If abortion permissible?

Even ≥120 days in rape; ≤120 days if life of mother at risk due to SFA. *Egyptian law prohibits abortion under any circums-tance but allowed to save life of mother. Egyptian clergy objected to law legalizing TOP for financial & health reasons [65]

≤120 days

≤120 days only

i. ≤120 days only

i. ≤120 days if foetus will die; SFA incurable

Extremes variations noted;

≥120 days

TOP ≤120 days if life of mother or health at (18/47 countries); whereas some countries (10/47) allowed TOP on request [50]. 1 in 10 pregnancies resulted in abortion in in the Middle East where TOP is not permitted, unsafe TOP was cause 6% of the maternal mortalities [61]

ii. SFA/dev delay

ii. ≥120 days if mother certain to die without TOP

If proven by 3 medical specialists & consented by both parents

≥120 days if risk to mother’s life proven by 2 medical specialists

iii. if it causes extreme suffering to mother and fetus

iii. TOP permissible any time if foetus died intra uterine.

iv. TOP can only be performed if recommended by 3 physician; if consented by both parents or wife alone if the pregnancy will harm her health or by or any person(s) delegated by parents

iv. Mother’s life at risk

Illegal /unsafe TOP rampant in many Middle Eastern countries often requiring hospitalization [62–64]