Understandings of self-managed abortion as health inequity, harm reduction and social change

January 14, 2019

Congratulations to Joanna N. Erdman, Kinga Jelinska and Susan Yanow, whose commentary was published in November issue of Reproductive Health Matters entitled “SRHR for all? Exploring inequities within countries.”  Professor Erdman is  Associate Director of the Health Law Institute at the University of Dalhousie; Kinga Jelinska, a cultural anthropologist, works with Women Help Women; and Susan Yanow, founding executive director of the Abortion Access Project, consults with non-governmental organizations.  We are pleased to circulate the abstract:

Joanna N. Erdman, Kinga Jelinska & Susan Yanow (2018): Understandings of self-managed abortion as health inequity, harm reduction and social change, Reproductive Health Matters 26.54 (Nov. 2018): 13-19.   Article online.

“This commentary explores how self-managed abortion (SMA) has transformed understandings of and discourses on safe abortion and associated health inequities through an intersection of harm reduction, human rights and collective activism. The article examines three primary understandings of the relationship between SMA and safe abortion: first SMA as health inequity, second SMA as harm reduction, and third SMA as social change, including health system innovation and reform. A more dynamic understanding of the relationship between SMA, safe abortion and health inequities can both improve the design of interventions in the field, and more radically reset reform goals for health systems and other state institutions towards the full realisation of sexual and reproductive health and human rights.”

The full text of this 6-page article is online here.

Related Resources:

Reproductive Health Matters 26.54  “SRHR for all? Exploring inequities within countries.”  (Nov. 2018)  Table of Contents online.

“A tough job: recognizing access to abortion as a matter of equality. A commentary on the views of the UN Human Rights Committee in the cases of Mellet v. Ireland and Whelan v. Ireland,” by Katarzyna Sękowska-Kozłowska,  Reproductive Health Matters 26.54 (Nov. 2018): 25-31.  Article online.

“Federalism, two-level games and the politics of abortion rights implementation in subnational Argentina, by Alba Ruibal, Reproductive Health Matters 54 (Nov. 2018): 137-144.  Article online.

Compiled by the Coordinator of the International Reproductive and Sexual Health Law Program, reprohealth*law at utoronto.ca For Program publications and resources, see our website, online here. TO JOIN THIS BLOG: enter your email address in upper right corner of this webpage, then check your email to confirm the subscription.

“Conscientious objection, Harm reduction and abortion care,” by Ruth Fletcher

October 31, 2018

Congratulations to Ruth Fletcher, Senior Lecturer in Medical Law at Queen Mary University of London, whose chapter is currently online through SSRN, with the following abstract:

Ruth Fletcher, “Conscientious Objection, Harm Reduction and Abortion Care,”  in Mary Donnelly and Claire Murray eds., Ethical and Legal Debates in Irish Healthcare: Confronting Complexities (Manchester: Manchester University Press, 2016) pp. 24-40.   Pre-publication version online

The scope of any legal right to refuse abortion care merits particular consideration given the passing of the Protection of Life During Pregnancy Act 2013 (PLDPA).  Irish health scholarship and practice may benefit from an account of conscientious objection (CO) that clarifies when CO is legitimately engaged by a refusal to provide care and whether CO is limited, given its potential effect as a barrier to women’s lawful access to abortion. This chapter responds to these concerns by arguing for a harm reduction approach to conscientious objection.  Those who wish to refuse provision of healthcare in spite of a legal obligation, and those who wish to provide healthcare in spite of a legal prohibition, may be harmed by having to act against their most intimate convictions.  Moreover, public reasoning about the proper scope of healthcare provision could be disadvantaged by a failure to recognize a space for critical consciousness.  The need to reduce the risk of harm to women, whose lawful entitlement to access abortion has been hard-won, also animates the justification for legal limits on CO.  In arguing for a harm reduction approach, the account offered here draws on but distinguishes itself from those who have relied on public obligations to refute CO and those who have relied on an individual right to moral integrity to ground CO.

A pre-publication version of this chapter is online here

More information about the book Ethical and Legal Debates in Irish Healthcare: Confronting Complexities is available from Manchester University Press.

Our Annotated Bibliography on “The Right to Conscience,” updated in 2018  is online here.

Compiled by the Coordinator of the International Reproductive and Sexual Health Law Program, reprohealth*law at utoronto.ca For Program publications and resources, see our website, online here. TO JOIN THIS BLOG: enter your email address in upper right corner of this webpage, then check your email to confirm the subscription.

Uganda: Harm reduction model for access to safe abortion

August 31, 2017

Congratulations and thanks to Moses Mulumba and his colleagues at the Center for Health, Human Rights and Development (CEHURD) in Kampala for collaborating with Dr. Charles Kiggundu, a gynecologist and obstetrician, on a newly published article in the Legal and Ethical Issues section of the International Journal of Gynecology and Obstetrics.

Access to safe abortion in Uganda: Leveraging Opportunities through the Harm Reduction Model” by Moses Mulumba, Charles Kiggundu, Jacqueline Nassimbwa and Noor Musisi Nakibuuka, International Journal of Gynecology and Obstetrics 138 (August 2017): 231–236.  PDF free online for 12 months Submitted text  online at SSRN.

Access to safe and legal abortion services is a far reach for women and girls in Uganda. Although unsafe abortion rates have fallen from 54 to 39 per 1000 women aged 15-45 years over a decade, absolute figures show a rise from 294 000 in 2003 to 314,000 women having unsafe abortions in 2013.  Unfortunately, only 50% of the women who develop abortion complications are able to reach facilities for post-abortion care.  Despite the clinical evidence and the stories from undocumented cases, debate on access to safer and legal abortion is constricted, moralized, and stigmatized.  The harm reduction model has shown evidence of benefit in reducing maternal mortality and morbidity due to unsafe abortion while addressing related stigma and discrimination and advancing women’s reproductive health rights.  This article presents a case for promoting the model in Uganda.

Key words:  Abortion laws; Abortion policies and guidelines; Constitutional rights; Ethics; Harm reduction model; Human rights; Ugandan abortion law; Unsafe abortion

Court decisions, Events, Fellowships, Resources, News & Jobs

December 19, 2012

December 19, 2012


European Court of Human Rights, Z v. Poland, Application no. 46132/08, Judgment of Nov 13, 2012.  Woman died due to being refused diagnostic care and treatment for disease due to pregnancy, but Court did not find violation of article 2 (right to life).  
Decision online.     Comment from Center for Reproductive Rights  

European Court of Human Rights, I.G. and Others  v.  Slovakia, Application no. 15966/04, Judgment of Nov 13, 2012.  Sterilizations of Roma women without informed consent violated their human rights.  Decision online.      Brief summary by law student

Solomon Islands, High Court:  Regina v. Gua [2012] SBHC 118, 8 October 2012.   Rule exempting husbands from liability for rape on their wives is no longer applicable; it is no longer supported by common law and offensive to modern standards and principles of equality found in international conventions and the Constitution. (based on summary by Interights)    Full text of decision online.


“Sexual Violence in the Recent Conflicts in Libya and Syria: Challenges to Protecting Victims & Protecting Accountability,” organized by the International Human Rights Program,  Faculty of Law, University of Toronto, Canada, Bennett Lecture Hall, on February 8, 2013 (8:30 a.m.-6:00 p.m.).   More information

“Bodies of Law: Women’s Health & Equality” Feminist Legal Studies Conference, Queen’s University, Kingston, Ontario, Canada
March 1-2, 2013.     More information


Brocher Foundation – 1 to 4 month residencies in 2014 (Bioethics, medical ethics, Law) for researchers (PhD students to Professors) who wish to work on projects on the ethical, legal and social implications for humankind of recent medical research and new technologies.
Overview online.      Fellowship details.  

Erasmus Mundus Master of Bioethics for the academic year 2013-2014, organized by the Katholieke Universiteit Leuven (Belgium), Radboud Universiteit Nijmegen (the Netherlands) and the Università degli Studi di Padova (Italy).  Apply by Jan. 15, 2013.  
Program Overview.      Scholarship information

Global Health Fellows,  2013-2014,  O’Neill Institute for National and Global Health Law at Georgetown University, Washington DC, USA.  Apply by Feb 22, 2013.   Fellowship details.

Women’s Human Rights Education Institute held in Toronto, Canada, May 22 – June 28, 2013 (6 weeks) Apply by Jan 31, 2013.  
Details online.       Scholarship information


[abortion]   “Harm reduction: A novel approach to addressing unsafe abortion,” editorial in Medical Abortion Matters, Nov 2012   Article online.

[abortion]   “Ireland’s Restrictive Abortion Law – A Threat to Women’s Health and Rights?” by Rie Yoshida, Clinical Ethics 6.4 (Dec 2011): 172-178.   Article online.

[abortion – Latin America]  “ ‘The health exception’: a means of expanding access to legal abortion,” by Ana Cristina González Vélez,   Reproductive Health Matters 40(Dec 2012): 22-9.   Abstract online.

[abortion – Mexico] “On Abortion: Exploring Psychological Meaning and Attitudes in a Sample of Mexican Gynecologists” by Ma. Luisa Marván, Asunción Álvarez del Río and Zaira Campos, Developing World Bioethics, Abstract and early view for subscribers: 22 Nov. 2012

[abortion – Sri Lanka] “Misoprostol and the politics of abortion in Sri Lanka by Ramya Kumar, Reproductive Health Matters 40 (Dec 2012): 166-174.   Abstract online.

[abortion & Catholicism] “The Secret History of Sex, Choice and Catholics,” documentary-style film examines Catholic traditions and teachings on key issues: e.g. abortion & contraception, HIV/AIDS, sex & sexuality, new reproductive health technologies, and religion in public policy.  46-minute film online.  (To watch 2-minute clips on specific topics, scroll down on same page.)

“Abortion and Regret,” by Kate Greasley, Journal of Medical Ethics 38 (2012) : 705-711.  Abstract and Article

[conscience]  “Taking Conscience Seriously,” by Elizabeth Sepper, Virginia Law Review 98 (2012): 101-170.   Abstract and article online. 

[conscience]  “Recognizing Conscience in Abortion Provision,” by Lisa Harris, New England Journal of Medicine 367 (Sept 13 2012): 981-983.  Abstract and article online

[conscientious objection]  “When a Health Professional Refuses: Legal and regulatory limits on conscientious objection to provision of abortion care”  by Patty Skuster, Ipas, Chapel Hill, NC.
16-page Ipas report

Conscience and Conscientious Objection 
list of our publications and projects, with links.

[emergency contraception]  “El Status Jurídico de la Anticoncepción de Emergencia en América Latina” por Martin Hevia.  Texto traducido y reproducido con autorización de la Federación Internacional de Ginecología y Obstetricia (FIGO)   Spanish translation
 — “The Legal Status of Emergency Contraception in Latin America,” by Martin Hevia, International Journal of Gynecology and Obstetrics 116 (2012): 87-90. English original

Emergency contraception: The story of a global reproductive health technology –  in 14 countries: Australia, Bangladesh, Britain, Chile, Canada, Jamaica, Lebanon, Mexico, Morocco, Nigeria, Tunisia, Thailand-Burma border, United States.   Publisher’s Information

Emergency Contraception
list of our publications and projects, with links.

[HIV+ pregnancy] “Pregnancy decisions of women living with HIV,” ed. Sofia Gruskin and Marge Berer, Supplement to Reproductive Health Matters 39 (Dec 2012), now available.   Table of Contents.

“International Human Rights Law: Towards Rethinking Sex/Gender Dualism and Asymmetry,” by Dianne L. Otto,  in A Research Companion to Feminist Legal Theory, M. Davies and V. Munro (eds.), forthcoming, Ashgate 2013.  Abstract and article online.


Colombia opens first abortion clinic – News article

Costa Rica: petition campaign to help “Aurora,” woman suffering with a nonviable fetus to have therapeutic abortion (supposedly legal in Costa Rica).  More information and call to action

Ireland:  Savita Halappanavar, a 31-year old dentist from India, denied termination during incomplete miscarriage at 17-weeks, died in University Hospital Gallway last month.  News article.

Ireland: Another Irish abortion scandal emerges: The Irish Government has paid substantial compensation to a cancer victim, Michelle Harte, endangered by pregnancy, refused abortion and cancer treatment, could not travel for abortion until it was too late.  Her lawyers sued last year for infringing her rights under the A B & C decision.  News article.

Ireland: Government pledges to allow abortions in life-threatening cases, including suicide risk  News article    Analysis

Luxemburg has adopted abortion on request within 12 weeks, Nov. 22, 2012,  Parliament voted 39 : 21 to change its abortion law of 1978.   After 12 weeks, abortion is legal for medical reasons.  
News article in German.

Mexico – interactive computer game, released by Ipas Mexico, provides youth with info on medical abortion.   Press release

Philippines: Reproductive Health bill approved on second reading in Congress 113-104 (Dec 12, 2012).  News article

Philippines:  Senate votes 13-8 for RH Bill on third and final reading (Dec. 17, 2012)  News article.  

Safe and unsafe induced abortions – global and regional levels 2008 and trends 1995-2008.   8-page WHO Information sheet.

Unsafe abortion incidence and mortality – Global and regional levels in 2008 and trends.   8-page WHO Information sheet

US-focused news, resources, and legal developments are available on Repro Rights Prof Blog.  View or subscribe.


Program Officer, Law and Health Initiative & Sexual Health and Rights Project,  The Open Society Foundations, New York, NY, USA.  Apply by Dec. 31, 2012.   Job details.

Links to other employers in the field of Reproductive and Sexual Health Law are online here
Compiled by the Coordinator of the International Reproductive and Sexual Health Law Program, reprohealth*law at utoronto.ca     
For Program publications and resources, see our website here.

Court Decisions, News, Resources, Calls, Events, Fellowships & Jobs

November 9, 2012


Colombia:  Constitutional Court reaffirms the obligation of the Inspector General to provide right information on sexual and reproductive rights and health.  
Summary of the decision at Women’s Link

European Court of Human Rights: 
Case of P. and S. v. Poland, no. 57375/08, [2012] E.C.H.R. 1853.
Raped teenage girl should have been given unhindered access to abortion Decision online      ECtHR Press Release
Case Summary by Y.Y. Chen,  Comments, and Press releases


Argentina:  Judicial Council will investigate a judge who tried to restrict abortion access for a 12-year-old whose pregnancy was the result of rape.   News article in Spanish

Poland:  bill restricting abortion in cases of serious fetal damage  – defeated  Press release from federa.org

UN  Human Rights Council adopts resolution on “traditional values”  while awaiting expert report on traditional values in March 2013.  Traditional values can be used to interpret,  reinforce or weaken  human rights.  ISHR press release    Text of the Resolution.

Uruguay:  Uruguay decriminalised abortion
New law in Spanish, online here.     Newspaper article in English
–New Abortion law breaks ground for women’s rights but burdensome procedures could undermine access.  Human Rights Watch analysis

US-focused news, resources, and legal developments are available on Repro Rights Prof Blog.  Subscribe or view here.


[abortion] “Think About It”  Ipas Brazil’s clever “Vai Pensando ai” video campaign, now in English, shows anti-choicers surprised by consequences of illegal abortion.
30-second English video
30-second Portuguese video

[abortion – Argentina] Argentine province-by-province reports on the application of abortion protocols and additional requirements brought by conservative groups, including time limits on termination of pregnancies, among others.  Clarin newspaper report in Spanish    “Progress and setbacks for access to legal abortion” 
Pagina 12 article in Spanish.

[abortion, harm reduction] Maternal mortality, Unsafe Abortion and the Harm Reduction Model: the Legal Platform – Materials to legally support health professionals tasked with the implementation of the harm reduction model to prevent unsafe abortion.
50-page report from Women’s Link Worldwide

[abortion – harm reduction] Access to Information on Safe Abortion: A Harm Reduction and Human Rights Approach by Joanna N. Erdman, Harvard Journal of Law & Gender, Vol. 34, pp. 413-462, 2011,  available on SSRN.

[abortion]   Harm reduction and abortion by Deborah Diniz, Developing World Bioethics, editorial online.

[abortion – Japan]   History of abortion law in Japan – overview online

[abortion stigma] Abortion and Disgust by Courtney M. Cahill,  Harvard Civil Rights-Civil Liberties Law Review, Vol. 48, 2013 
Article online at SSRN.

[abortion stigma] Doctor’s Dilemma – Stigma in Asian  Hospitals 
Asian Safe Abortion Partnership – ASAP blog post

[abortion stigma] Canadian women have been challenging abortion stigma by publishing their stories & photographic portraits online at Arts4Choice.  Now calling  for Participants for forthcoming book 
 See arts4choice.com

[child marriage] UNFPA:   Marrying too Young – End Child Marriage, mentions international agreements, national laws, law enforcement, customary law 74 page report, 2012   includes legal and policy reforms for each country.

“Evidence-Based Advocacy: Expanding Our Thinking About “Repeat” Abortions,” by Steph Herold.  RH Reality Check blog

International Reproductive and Sexual Health Law Programme: Publications page.

[IVF – Latin America]  “The Legal Status of In Vitro Fertilization in Latin America and the American Convention on Human Rights” by Martin Hevia and Carolos Herrera Vacaflor,  Suffolk Transnational Law Review Forthcoming, but now available at SSRN

(Nigeria) Substantive Equality and Maternal Mortality in Nigeria, by Ebenezer Tope Durojaye. Journal of Legal Pluralism and Unofficial Law, Vol 65, pp. 103-132, 2012. Abstract  available at SSRN  

Sex Work and the Law in Asia and the Pacific:  Laws, HIV and human rights in the context of sex work, by John Godwin, 2012.  This new UNDP/UNFPA/UNAIDS report examines links between sex work, HIV and the law in Asia and the Pacific, and analyzes how current laws, policies and practices help or hinder HIV responses
Press release      226-page report 


McGill Journal of Law and Health is now accepting submissions in French or English  Submission information

Arts4Choice is calling for participants for forthcoming book of abortion stories by ordinary Canadian women with portraits by photographer K Palmateer, aiming to reduce stigma.   details online at arts4choice.com


“The Right to Abortion and the Right to Contraception” Critical Thinking Forum, Cape Town, South Africa, 13 November 2012, 4 pm for 4:30 till 20:30. RSVP mahlodimATmg.co.za   More information


Postdoctoral Fellowship, The Petrie-Flom Center for Health Law Policy, Biotechnology, and Bioethics at Harvard Law School
2-year fellowship for persons interested in pursuing academic careers in this field.  Apply by November 16, 2012. 
Application materials     Information about Petrie-From Center


Global Advocacy Director within the Global Legal Program.  For more information about duties and responsibilities, requirements, and how to apply, visit our website. Applications will be accepted through November 16, 2012.  Job information

Lecturer/Practitioner in Residence, University of Miami Human Rights Clinic, 2 years, renewable, starting Summer 2013, U.S. legal training required. Apply by Dec. 14, 2012. Job details online.

Links to other employers in the field of Reproductive and Sexual Health Law are online here

Compiled by the Coordinator of the International Reproductive and Sexual Health Law Program, reprohealth*law (a) utoronto*ca
For Program publications and resources, see our website here.

Decisions, Calls, Courses, Resources, News & Jobs

August 17, 2012


August 17, 2012


Namibia HIV+ sterilization:
LM and Others v Government of the Republic of Namibia
[2012] NAHC 211   High Court, 30 July 2012.
Sterilizations of HIV+ women during childbirth, without informed consent
Decision online      

Uganda: maternal mortality petition to Constitutional Court rejected.
Centre for Health, Human Rights and Development and Ors v Attorney General [2012] UGCC 4   Constitutional Court, 5 June 2012
(Description by Interights:)  Petition alleging constitutional violations arising from inadequate state provision of maternal health care struck out, on the basis that entertaining it would encroach on the domain of the Executive and Legislature and would thus fall foul of the ‘political question’ doctrine.    Decision online.


IPPF needs volunteer lawyers or graduate law students to research laws & regulations that impede young people’s access to sexual & reprohealth  services in: Afghanistan, Albania, Bolivia, Bosnia, Canada, Chile, Colombia, Dominican Republic, Egypt, Ethiopia, Ghana, Guatemala, India, Indonesia, Kenya, Malawi, Mozambique, Nepal, Pakistan, Peru, Philippines, Senegal, Vietnam & Zambia.  Details online.

WHO Safe Abortion Guidance: Clinical Recommendations Webinar with Dr. Nathalie Kapp, Wed Aug 29 2012, 9- 10:00 am EST
Email your name, title, org. affiliation and contact info to servicedeliverymatters@ipas.org by Aug 28.

“The Legal and Ethical Implications of Posthumous Reproduction” Call for papers for symposium issue of Journal of Law and Health, Email your 600-word abstract and CV by October 1, 2012 to health.journal@law.csuohio.edu with subject: “Submission: Annual Symposium”.

Course:  CEDAW for Change – one week intensive course: Women’s Human Rights Education Institute
Nov 5 – Nov 9, 2012, Toronto Canada.  Course information.


Criminal Laws and Women’s Right to Health – Report from ACPD side event at the UN Human Rights Council
includes links to presentations by UN Special Rapporteur on the Right to Health, IFPA and Ipas, plus full report of UN Special Rapporteur on the Right to Health.  ACPD Report with links.

“Expanding Access to Medical Abortion: Perspectives of women and providers in developing countries” Special Supplement of the International Journal of Gynecology and Obstetrics (IJGO) -10 papers.
Click here, look upper right, find Supplement title under “View for Free”

“Harm Reduction, Human Rights, and Access to Information on Safer Abortion,” by Joanna Erdman. International Journal of Gynecology and Obstetrics 118 (2012): 83-86.   Abstract and Full text online.

FIGO  Prevention of Unsafe Abortion Initiative – Situational analyses of induced and unsafe abortion and/or national plans of action, of which 27 are now online:  Argentina, Benin, Bolivia, Brazil, Cameroon,Chile, Colombia, Egypt, Ethiopia, Gabon, Kenya, Mozambique, Nepal, Nigeria, Pakistan, Peru, South Africa,Sudan, Syria,  Tanzania, Thailand, Tunisia, Turkey, Uganda, Uruguay, Venezuela & Zambia.  Analyses online.

“Gender Stereotyping and the Federal Judiciary in Mexico,” by Denise Gonzales Nunez, Mexican Law Review 3.2., 265-296.  Article online.

Interights’ searchable International and Commonwealth case databases now contain over 2500 summaries of human rights decisions.
Database info and access

International Reproductive and Sexual Health Law Programme – Publications online in English      Spanish translations

The Meaning of ‘Life’: Dignity and the Right to Life in International Human Rights Treaties,  by Elizabeth Wicks,  Human Rights Law Review 12.2 (June 2012): pp 199-219   doi: 10.1093/hrlr/ngs002
Article or abstract.

Special Report on Sexual and Reproductive Health (6 pp) mainly contraception, also FGC, published in Financial Times July 9, 2012.  Financial Times Special Report


China: Forced abortions and sterilizations in China – Women’s rights group submits complaint to UN Commission on the Status of Women  News item. 

Kenya – New abortion hotline launched. Women on Waves press release

Poland – worldwide petition promotes new bill liberalizing Poland’s abortion law.  Petition information in English.

Rwanda Lifts Reservation on Abortion Provision in Maputo Protocol – another critical step toward liberalizing its abortion law
CRR press release online     CRR  Further background 

Zimbabwe relaxes abortion laws:  hospitals will no longer report illegal abortions to police.  News item.


Legal Director, Equal Rights Advocates, San Francisco CA, USA.  Job information

President & CEO Reproductive Health Technologies Project, Washington DC, Apply by Sept 7, 2012.  Job announcement

Legal Research Director, UCLA School of Law, Williams Institute on Sexual Orientation and Gender Identity Law and Public Policy, apply by Sept 28, 2012.  Job information

Links to other employers in the field of Reproductive and Sexual Health Law are online here.


Compiled by the Coordinator of the International Reproductive and Sexual Health Law Program, reprohealth.law AT utoronto.ca  Visit our Website 

Nigeria: HIV, Prostitution, and Drug Use

July 31, 2012

Congratulations to Dr. Babafemi Odunsi, an LL.M. graduate of our International Reproductive and Sexual Health Law Program who now teaches law at Obafemi Awolowo University in Nigeria.  We thank him for sending the following abstract of his recently published article.  The author can be reached at:  femiodunsi 2002 at yahoo*com.


By Babafemi Odunsi

Malawi Law Journal 4.2 (2010): 215-232.

This article examines the interplay between prostitution, injection drug use and the spread of HIV/Aids in Nigeria. It also considers how Nigerian criminal law and the unfriendly social attitude to prostitution and illicit drug use vitiate the control of HIV/Aids. The article stresses the need for Nigerian criminal law to maintain a ‘soft stance’ on sex workers and drug users in order to accommodate their needs and vulnerabilities relating to HIV/AIDS. It underscores the need to put the overall public health interest in effectively controlling the spread of HIV over and above the social aversion to prostitution and illicit drug use – an aversion which Nigerian criminal law reflects and reinforces.