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A Dangerous Compromise: The Battle of Reproductive Rights in Poland

“I’ve never heard of it and I’ve lived here my entire life. You must have the wrong address.” We were looking for the Polish Federation of Women and Family Planning, the largest reproductive rights organization in Poland. When we asked for directions, in search of a helpful voice to point us in the proper direction, or to give us any information at all, the public had few answers. Finally, after forty minutes of circling the block (and the surrounding blocks), re-examining the map, and re-checking the address, we resigned to calling a friend. “Oh yes, it is very difficult to find.” She gave us detailed, step-by-step directions. Soon enough, twenty feet from where we had asked multiple people for directions, there it was: discreetly tucked away in an old, square building, hardly noticeable to the average passerby. 

Two thousand kilometers away, in that same week, the front page of the June 18, 2008 Irish Times reads: “A 14-year-old pregnant girl, who says she was raped by a friend, is caught in the middle of a struggle between Poland's anti-abortion and pro-choice camps”.  Known by the public as “Agata,” a pseudonym created by the press, this girl’s pregnancy and subsequent abortion, has once again brought the fraught politics of reproductive rights in Poland to the center of civil discourse. Such language as “caught in the middle” suggests a simple, two-sided issue: the side of pro-life, and the counter side of pro-choice, a one-on-one debate which ignores the many other aspects of reproductive rights. However, looking deeper into the language of reproductive rights in Poland – or lack thereof – reveals a large and entangled web of issues far more complex than a two-sided abortion debate. This narrow discourse has created a system nearly impossible for women to navigate, and even more difficult for activists to change. 

In 1993, under the Family Planning Act, Poland went from having one of the most liberal abortion policies in Europe to one of the most restrictive.  Professor and reproductive rights activist, Andrzej Kulczycki, notes that “June 4, 1989 marked the end of Communism in Poland. Since then, those favoring women’s right of choice in Poland have faced a paradox. The political changes that resulted in the establishment of a democratic state have brought about restrictions on women’s rights as an unexpected side-effect.”  The shift to democracy and the freedom it signifies in Poland has placed the politics of a woman’s body in a contradictory situation: where democracy signifies liberty, for women, the shift to democracy has brought restrictions upon their bodies that haven’t existed since 1956. Sketch a drawing of the current reproductive rights situation of Poland, and one will find: a thriving underground market where abortion is accessible but expensive; a place where contraceptives are hard to find; maternity wards lacking in resources and funds; and abstinence-only based sexual education programs, if sexual education is taught at all. Reproductive rights occupy the frontlines of the human rights discourse precisely because of the many human rights violations surrounding the issues, yet the status quo has been accepted by the current social and political systems in Poland. 

A Battle over Language

This report is not centered on the abortion debate, but rather on reproductive rights. In Poland, however, the battle of reproductive rights has become a battle over language and a battle over abortion rather than over the multiple aspects of reproductive rights: sexual education, access to and availability of contraceptives, conditions of hospitals, and more. Warsaw University Law Professor Eleonora Zielińska states that “in Polish legal language there is no such concept of ‘reproductive rights’ understood as the right to the protection of reproductive health and self-determination in reproductive matters.”  Instead, the discourse is centered within the abortion debate as presented by the media. This limited framework ignores the larger dynamics of a reproductive rights discourse, and also, because Poland is a Catholic state, places the discourse within the language provided by the Church.

Agnieszka Graff, a professor at Warsaw University and a women’s rights activist, comments that “the Church realized this was a battle over language before the feminists did.”  The Church acted early to place its own point of view into the media by systematically using its own language. This is seen through the media’s frequent use of terms like “unborn child” and “conceived life,” which focus only on the fetus, rather than such terms as “pregnant woman,” which would take into account the woman along with the fetus. As a result, the Church’s way of thinking has become the default, and abortion to pro-lifers has been dubbed “the civilization of death.”  

The Warsaw Voice illustrates the events of the 8th of March, International Women’s Day, what has become a day of demonstrations and protests called “Manifa.”  Women’s rights activists have centralized the theme of reproductive rights in their demonstrations, one of their slogans this year being “3 X’s Yes.” Three times yes for “access to contraceptives, universal sexual education, the right to abortion and better quality of reproductive health care.”  However, Graff, an organizer of Manifa, notes that when “you mention ‘abortion,’ that’s all the media remember.” She says that it becomes a question of how to get the media to think in terms of all three, to think about how the three go together.  Media representations of reproductive rights, along with the failures of the legal language to address reproductive rights as a multi-faceted issue, leave little space for social and political discourse to address the many ways in which reproductive health could be improved. Adam Bodnar from the Helsinki Foundation for Human Rights adds: “People go straight to abortion, they skip over contraceptives, they don’t think about education. This is a reflection of the system. Abortion, surely, is the key issue, but what about all the other aspects?” 

A Strong Church and Limited Public Consciousness

An historical look at reproductive rights in Poland shows how Poland has come to the state of “compromise” it is in today, where neither pro-life nor pro-choice activists are content. 

In 1956, under the Condition of Permissibility of Abortion Act, abortion in Poland became legal on the grounds of health, legal, and social issues, making abortion available on demand.  This 1956 shift in law overturned the ban on abortion which had been in effect since 1932, when the first Polish regulation of abortion was implemented. From 1956 to 1993, throughout most of the communist regime, abortion was legal and subsidized by the state. Women from all over Europe came to Poland for abortions. 

When the abortion law was liberalized in 1956, it was, in a sense, “given” to society. There were few social movements that had fought for its liberalization and people took for granted what had seemed an ordinary right, says Aleksandra Solik of Karat Coalition for Gender Equality.  This mentality combined with the rising influence of the Catholic Church provided for little social movement in the 1990s when the abortion law again came under political scrutiny, and once more faced the threat of becoming illegal. Aleksandra Solik of Karat Coalition for Gender Equality notes that since there was little to no public discourse about abortion in the years leading to 1989, the debate was not in the public’s consciousness; people were unprepared to fight for a right that had, until this point, seemed ordinary.

In 1993, the majority of society, “despite its Catholicism, did not support the ban on abortion, [but] the direct involvement of the Church in the activities against reproductive rights, and particularly, the role of Pope John Paul II, impeded the establishment of a stronger, better organized and more effective pro-choice movement”.  In 1992, leaders of the pro-choice movement created an initiative which sought to bring into the public’s consciousness the frail state of reproductive rights.  Barbara Labuda and Zbigniew Bujak, both liberal Members of Parliament and former oppositionists, spearheaded the motion, and in just a few weeks they, among many activists, had gathered over one million signatures. Solik, a petitioner for the referendum, said that what was so unique about the initiative was that people who were often not active in this type of issue, “a woman’s issue,” mobilized to join the initiative.  Mass quantities of people worked together to bring into awareness an issue that often existed beyond the public’s consciousness. Although the movement reflected astonishing grassroots action by the people, the organizing fell short of preventing the ban on abortion which ultimately passed in 1993. However, notes Solik, it is thanks to this initiative that abortion was not banned completely, and is still legal under certain conditions.  

There are three exceptions to the 1993 Family Planning Act (Protection of the Human Fetus and Conditions Permitting Pregnancy Termination). These exceptions, as they stand today, read:

An abortion can be carried out only by a physician where:
- Pregnancy endangers the mother’s life or health; 
- Prenatal tests or other medical findings indicate a high risk that the fetus will be severely and irreversibly damaged or suffering from an incurable life-threatening disease;
- There are strong grounds for believing that the pregnancy is a result of a criminal act. 

With these three exceptions intact, the Act has become known as “the compromise”, having been formed from the merging of two contradicting drafts of similar bills – one liberal and one restrictive.  This state of compromise has created much tension in the abortion debate, especially considering the power of the Catholic Church in Poland. 

Beyond social reasons, the topic of abortion has stayed central in the political process for another reason: when many political candidates agree on topics such as the economy, foreign policy, and democratization processes, they turn to the abortion debate to distinguish themselves from the other candidates. Abortion, then, has played a crucial role in the crystallization of the Polish political system after communism as Poland entered a new democratic state, writes Professor Małgorzata Fuszara. 

A Cry for Education

Sexual education in Poland has been a topic of contention for pro-life, pro-choice, and reproductive rights activists throughout Poland’s reproductive rights battle. During communism the version of sexual education offered in schools could more accurately be called Preparation for Socialistic Family Life.  This subject, introduced into high schools in the 1970s, was a far cry from what a reproductive rights advocate might hope for in the education system.  With the shift from communism to democracy, sexual education made the large leap into a subject now called Preparation for Family Life. With Catholic values at the core of the lessons, it is still a long way from a pro-choice activist’s idea of proper and effective sexual education. 

Some pro-choice advocates claim that the current reproductive rights issue would not be in such a bad situation if the influence of the Catholic Church and right-wing politicians did not hold sway over teachers and schools.  While the issue of sexual education is related to the Catholic Church and its influence over social issues, it is also an issue of proper training for teachers themselves. Even if granted the opportunity to teach sexual education from a secular perspective, many instructors would not have the knowledge or resources to do so. Schools are not obliged to prepare such lessons nor provide the resources for their students and teachers. Parents must also give permission for their child to attend these sexual education sessions. And quite often they do not, either to prevent their children from learning about the “civilization of death” if they are pro-life, or in order to keep their children away from the Church’s abstinence-based education if they are not. 

Law Professor Zielińska tells a story from the classroom. In the early 1990s, she would ask her students to raise their hands if they were in favor of the ban on abortion, and only a handful of students would raise their hands. But now, she adds, about fifty percent of students raise their hands in favor of the ban on abortion. Zielińska suggests that this shift in attitude is due in large part to the religious indoctrination at schools, adding that proper education could solve half of the problems with reproductive rights perceptions and execution in Poland.  

Alongside the role of sexual education in schools, Aleksandra Solik refers to the role of women’s magazines in informing women about their sexuality and reproductive rights. Solik notes, however, that access to magazines is limited to those who have money. The information on the internet can also function as a substitute for school education to some extent but, until it is accessible for all, it is a mere half-solution, which is no solution at all. 

Childbirth With(out) Dignity 

During communism, hospital conditions were hardly ideal. Today, there is still much work to be done in creating humane conditions for mothers giving birth in public hospitals. In their interviews, Solik and Zielińska both compare birthing conditions during communism to the conditions of a prison, and emphasize that there is still much progress to be made. Until the 1990s, women entering maternity wards of hospitals were shaved, locked in the maternity wards separate from all family, not allowed to wear their own clothes, and were forced to wear a short shirt with no pants under the claims of hygiene.  “It was a horror” said Zielińska as she recalled her own experiences giving birth.  

In 1993 the Gazeta Wyborcza, Poland’s largest daily newspaper, compiled a guidebook of hospitals with maternity wards and asked readers to submit letters describing their experiences giving childbirth in hospitals. These letters formed the foundation of a vast social campaign called Giving Birth with Dignity (Rodzić po ludzku), which is now referred to as one of the most successful social campaigns in Poland after the 1989 Solidarity Movement.  The movement improved hospital conditions for mothers, but there remain huge steps to take in humane birthing conditions for all women. 

The improvements that have been made often only impact women able to pay for the better conditions. Those women who cannot afford the improved maternity wards or private clinics often do not have the opportunity to give birth with “dignity.”  While these harsh hospital conditions are a reflection of an under-funded health and medical system, it is interesting to note what (and who) gets spared first: in this case, it is the women and their children, and the resources that go into maternity wards. 

In the Giving Birth with Dignity campaign, what is striking are the enormous advancements made because of the grassroots mobilization of people. Huge strides towards a humane childbirthing process came as a result of people’s activity and organizing. It was through the refusal of, and the raising of public consciousness about, an oppressive medical system that created the necessary change, rather than mere policies of politicians. Through the great effort of women who collectively struggled toward a common goal, the social system changed and conditions improved for women today. Such a movement, Środa adds, is a rare occasion in today’s Poland.  

A Drop in a Large Pool of Water: Lack of Information, Limited Access to Contraceptives

The public’s literacy concerning contraceptive methods is quite limited. It takes individual effort, awareness, and money to find effective, accessible, and affordable contraceptives, and there is no political or social ideology surrounding the issues of contraceptives.  “Nothing has changed” from communism to democracy in terms of the availability and visibility of contraceptives, says Solik, but what has changed is the availability of information through the internet, through women’s magazines, and through the activism of NGOs. But even this, adds Solik, “is a drop in a large pool of water.” 

In examining the accessibility of contraceptives over the past eighty years in Poland, Środa notes that during the Stalinism era, as in every totalitarian system, women were denied any reproductive rights, abortion was penalized, and contraceptive methods were inaccessible. She adds that after the 1956 liberalization of abortion, contraceptives were introduced, as well as “K” health centers (“K” for kobieta or woman), which provided gynecological and educational consulting for women. However, through the 1980s and the events leading to Poland’s democratization in 1989, there was a gradual resignation from liberal treatment towards women’s reproductive rights as the Church’s role in the Solidarity movement brought the Church closer to the role of the state. 

Zielińska notes that “contraceptives in Poland before 1989 were not so wide-spread, and the population of Polish women who used the pill was very small and scarce”, not to mention that contraceptives were expensive. Abortion, on the other hand, was legal and embedded in the public’s consciousness.  Since “abortion was accessible and very easy” it became a means of contraception, when other methods, Western methods, were expensive, not well-known, and difficult to access.  Today, on the other hand, if a woman goes to a public doctor or health center, she likely will not obtain a prescription for contraceptives. But in a private clinic, where she pays approximately 50 PLN for one visit plus the cost of the prescription, she will likely receive her contraceptives without many problems.  This class barrier prevents women without the economic resources from visiting a private physician, causing problems in not only access to contraceptives, but also accessing an abortion in the case of an unwanted pregnancy. The situation as it stands is a troubling one, and one that will likely see little change in the current reproductive rights landscape. 

After 1989, with the influx of Western goods and the improvement of the pharmaceutical industry, Poland had a window of opportunity to introduce a widespread availability of varying contraceptive methods. However, rather than availability of, or information about, contraceptives came the entrance of Catholic family planning in the education system, and the alliance of John Paul II with the pro-life population of Poland. With this alliance between the Church and political ideology, alongside the loyalty that the majority of the Polish population holds for the Church, it becomes difficult even for the availability of information to create change.  In this social landscape, “information doesn’t solve the problem.” People need more than information: they need resources.  

The High Price of an Underground Market

Women with resources are often able to turn to the thriving “underground abortion market” where they have access to relatively safe but expensive abortions. The Polish Federation for Women and Family Planning estimates that 80,000 to 200,000 underground abortions are performed in Poland each year; yet the official count for legal abortions performed in Poland each year is approximately two-hundred.  This discrepancy points to the lack of enforcement in current restrictive abortion laws, giving way to a popular underground abortion market, and with that, an exploitation of women forced to function beyond regulated, monitored medical settings.
When it comes to getting an abortion, “who has money, has no problem”, says Środa.  “It is the poor women who pay for such restrictive [abortion] policies ... it is an issue of class.”  In placing abortion within a nearly entirely underground market, those who cannot secure the funds necessary for the procedure are those who pay the greatest price, often either seeking a cheaper abortion at the expense of safety, or going forward with an unwanted pregnancy. In this underground market, the same doctor who turns a woman away from his public office often performs abortions in his private office, but only for a high fee. The cost of an illegal abortion in Poland ranges from approximately 2000 to 5000 PLN, when the average gross monthly salary in Poland is at 2000 PLN. 

One aspect of the underground market that seems to reinforce restrictive policies is the lucrativeness of the industry. Doctors can charge any price they please, and women rarely have the option of shopping for a cheaper price. Aleksandra Solik tells a story of a woman who went to the doctor for a pregnancy test. The doctor told her she was pregnant, but said he could only perform an abortion in his private office. She went to his private office for the abortion, and he told her the procedure would cost 5000 PLN. Having the resources, and also the information, the woman thought this price seemed steeper than the prices she had regularly heard about. She told the doctor she would think about the abortion, and went to find another doctor in the underground market to perform the procedure. When she went to the second doctor, he informed her that he could not perform the procedure because she was not even pregnant. The first doctor had lied to her about her pregnancy to be able to charge her for an abortion. Solik notes that this is not the typical story, but it is emblematic of the loss of control women face, and their subjection to the physician’s power, when they must operate in the underground market. 
At a demonstration for Agata, a banner read: “Doctors Come Out from the Underground.” Such a statement attempts to summon the doctors of Poland to action, to stand up for reproductive justice away from the underground.  This type of demonstrating looks to join reproductive rights activists with the doctors of Poland in attempts to liberalize, or at least bring greater awareness to the situation of reproductive health in Poland today. But when doctors are the beneficiaries of such a system, it is difficult to mobilize them against that which brings in a large profit. Perhaps, notes Solik, it is not a question of right or wrong, life or choice, but rather a question of whether one person can make a difference, or if one person feels that they by themselves can make a difference. Solik comments that people in Poland are reluctant to speak out. At protests the same faces are seen day in and day out, and it is hard to get more than a few people actively involved in anything. 

Środa notes that, in order to understand the way in which the underground abortion industry is able to exist within the Polish political, social, and ideological systems, one must first understand the phenomenon of the underground in the history of Poland. Because Poles have lived for two-hundred years under various partitions and occupations, Poles have become skillful at skirting the law; in fact, it is even something in which they take pride. “If abortion is illegal, it is easy to evade,” remarks Środa.  In looking to explain the indifferent attitudes of mainstream society, Graff explains that “Poles are very pragmatic. If you can evade the law, why change it?” Such a situation, she adds, perhaps demobilizes the masses in working to liberalize the current reproductive rights situation.  This, however, is particularly interesting considering Poland’s reputation for creating one of the greatest social revolutions in modern history: the Solidarity movement. Some say, however, that “in Poland – in a sense – there is no abortion underground ... when something is so readily available, it can no longer claim a title to the ‘underground’.”  Everyone knows you can get an abortion if you have the money; pro-lifers want abortion to be illegal, but are not so concerned with the underground market. These restrictive policies are mere “symbolic politics,” suggests Graff. 

Katarzyna Bratkowska, director of Same O Sobie (Ourselves About Ourselves), an NGO working toward the liberalization of the abortion policy, comments that “the pro-life supporters actually do not protect life, it’s just rhetoric. The ban on abortion is not decreasing the scale, but only the quality of [abortion]. It’s not about protecting the conceived ‘children,’ it’s about punishing women who decide to have an abortion.”  Bratkowska draws attention to the way in which the 1993 ban on abortion has not brought about a new end to abortion, but rather an erosion of the already limited information provided, and a sharp increase of price. Graff also notes that although the underground market is widely known, doctors rarely get arrested and women do not go to prison for illegal abortions  (as compared to the United States when prior to the legalization of abortion, women’s lives were regularly threatened by backstreet abortions and women and doctors were frequently imprisoned for performing abortions). In Poland, however, enforcement is not the issue; the issue lies in political ideologies--what is stated in the law, and the way in which the Church perceives the state to function. In a sense, the reality of the situation is insignificant; what is written on paper is that which matters most.

Protect the Law and Protect Our Rights

Although reproductive rights fit within the human rights framework, some elements beyond the abortion debate do not easily enter the discourse. Sexual education and access to contraceptives in Poland, even within the human rights discourse, continuously fall to the margins. 
“Women’s issues are human rights” says Bodnar of the Helsinki Foundation for Human Rights. The Helsinki Foundation views the abortion rights problem in Poland as largely a question of access.  Bodnar cites many cases in which the Helsinki Foundation played a role in landmark reproductive rights cases in which, in their opinion, human rights were being violated. 

Bodnar presents one case, the 2005 landmark case of Alicja Tysiąc v. Poland, which ended in a decision by the European Court of Human Rights. Alicja Tysiąc, at the time of pregnancy in 2000, suffered from an extreme case of myopia. Doctors warned that the pregnancy and delivery of another child could result in a deterioration of her myopic eye condition.  When she sought an abortion, she was denied the right, even on the basis of the exception “where the pregnancy endangered the mother’s life or health.”  After being forced to carry out the pregnancy, Tysiąc’s eye-sight completely deteriorated. She then brought her case to the State Court in 2002, where her case was dismissed. Carrying her case further to the European Court of Human Rights, the court found her treatment by physicians, and their denial of her right to an abortion, unlawful and in violation of the European Convention on Human Rights. Tysiąc won 25,000 EUR in damages and a ruling that the Polish government “must not structure its legal framework in such a way as to limit” legal access to abortion. Poland had breached Tysiąc's rights by not having an effective mechanism to rule on whether she had met the legal conditions for a legal abortion.  But two years after this ruling, Poland’s abortion laws still leave much room for interpretation.
For the Helsinki Foundation the question is not whether the abortion law should be restrictive or liberalized, for that is an issue of politics, says Bodnar. The Helsinki Foundation and Bodnar instead emphasize the notion that women should have real access to abortion in cases when it is legal.  This then calls into question the compromise situation of Poland. The problem with the compromise is that “the Law’s provisions are not fully implemented and that some women, in spite of meeting the criteria for an abortion, are not subject to it. There are refusals to conduct an abortion by physicians employed in public health care system units who invoke the so-called conscience clause, while at the same time women who are eligible for a legal abortion are not informed about where they should go.”  
With such exceptions the issue becomes a matter of definition and language: how physicians should define “severely”; where the line should be drawn between “health” and “endangered health.” Such questions are at the center of Poland’s struggle to abide by international human rights treaties, and at the same time maintain the moral values of the Catholic Church and its commitment to the right to life. 

Bodnar says that reproductive rights are among the top five issues for the Helsinki Foundation. Rulings like the ones in Tysiąc v. Poland, and the Helsinki Foundation’s participation in such cases, make and keep reproductive rights a credible human rights issue: “It’s a real issue of human rights and not a feminist’s ugly civilization of death.”  

Finding Space for Change

Poland’s reproductive rights discourse is embedded in an historic and social framework that allows for little progress. Entrenched in a Catholic ideology that views reproductive rights as a “civilization of death”, and contending with doctors, politicians, law enforcers who do not often stand for women’s rights, a history that prides itself in evading the law, and an underground market where abortion is readily available, Poland’s reproductive rights organizing has little space to create a cohesive and powerful movement. 

When Agata, the fourteen year old victim of rape, finally received an abortion after much public scrutiny, she received pro-life harassment and a denial of her legal rights by physicians.  What became overwhelmingly clear is that when it comes to reproductive rights, women work within a system that prioritizes social ideology over their legal rights. “The government accepts that women have these limited rights to abortion under the law, but says it doesn't have an obligation to make these rights real," says Wanda Nowicka.  “All I want,” adds Anna, the mother of Agata, “is for our public servants to perform their duty.” 

In 2004 the United Nations Human Rights Committee “reiterate[d] its deep concern about restrictive abortion laws in Poland”, and suggested that “[t]he state party should liberalize its legislation and practice on abortion.”  However, when asked if the situation of reproductive rights in Poland might improve, most pro-life people interviewed answered with an abrupt “no.” Despite pressures to change its policies from the Human Rights Committee, Women’s Organizations, and various NGOs, as it stands today, few changes have been made, and activists struggle to remain optimistic.

Some had hoped that the accession to the European Union in 2004 would improve the situation, adopting human rights ideologies into the framework of Poland. But such changes were impeded under the conditions that "No EU treaties or annexes to those treaties would hamper the Polish government in regulating moral issues or those concerning the protection of human life."  Since the EU accession, some pro-choice activists lamented that in some ways the situation of reproductive rights has only become worse, as the accession in a sense legitimized Polish laws and their protection of pro-life ideologies. 

Bratkowska, on the other hand, says it is a matter of time: five, ten, fifteen, maybe twenty years.  The current situation is depressing, but the pressure from reproductive health advocates remains strong, even in the face of uncertainty and unyielding systems that work against the protection of women. Change, in this situation, lies in the hands of the feminists, the women’s organizations, and those who care to keep the issue alive.


Works Cited:

“Advocating for Abortion Access: Eleven Country Studies”, The Women’s Health Project, School of Public Health, University of the Witwatersrand, Johannesburg, South Africa (2001).

Kulczycki, Andrzej, “Abortion Policy in Postcommunist Europe: The Conflict in Poland


Population and Development Review”, Vol. 21, No. 3, (Sep 1995), pp. 471-505; published by: Population Council; Stable URL: http://www.jstor.org/stable/2137747.

Nowicka, Wanda, (ed.) “Reproductive Rights in Poland: the effects of the anti-abortion law”, Polish Federation for Women and Family Planning, (March 2008).
Zampas, Christina, Wanda Nowicka. “Sexual and Reproductive Rights in Europe: Report to the European Union.” Astra Network, (Jan 2006). http://www.astra.org.pl/srhrEU.pdf.

Legal Acts:

The Criminal Code 1997 in force; Polish Official Journal 1997, No. 88, item 553; (Dziennik Ustaw 1997, Nr 88, poz. 553).
The Criminal Code 1932; (Dz. U. 1932, Nr 60, poz. 571).
The Condition of Permissibility of Abortion Act; (Dz. U. 1956, Nr 12, poz. 61).
Case of Alicja Tysiąc v. Poland; European Court of Human Rights, Application No. 5410/03; Strasbourg, 20 March 2007. 
The Family Planning Protection of the Human Fetus and Conditions Permitting Pregnancy Termination Act – in force (Dz. U., Nr 17, poz. 78).
All to be found at: http://aktyprawne.rp.pl/aktyprawne/akty/index.spr?publikator=1.


“Abortion Issue Threatens Polish Admission to EU,” The Guardian (January 30, 2004),guardian.co.uk.
“Abortion Tug-of-War of Schoolgirl Raped in Poland,” Irish Times (June 18, 2008),http://www.irishtimes.com/newspaper/frontpage/2008/0618/1213735260037.html
“Tug-of-War Over the Right to Choose,” Irish Times (July 26, 2008),
“Women’s Day” Warsaw Voice (February 28, 2007), http://www.warsawvoice.pl/view/14069/


Adam Bodnar, Ph.D., Helsinki Foundation for International Rights, 6/27/2008.
Katarzyna Bratkowska, SOS, 7/1/2008.
Małgorzata Dziewanowska, Polish Federation for Women and Family Planning, 6/28/2008.
Agnieszka Graff, Philology Professor at Warsaw University, 6/30/2008.
Aleksandra Solik, Karat Coalition for Gender Equality, 6/26/2008.
with Magdalena Środa, Ethics Professor at Warsaw University, 6/29/2008, Online Interview.
Eleonora Zielińska, Law Professor at Warsaw University, 6/30/2008.
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