 Under European law, fetus is generally regarded as an in utero part of the mother and thus its rights are held by the mother.The European Court of Human Rights opined that the right to life does not extend to fetuses under Article 2 of the European Convention on Human Rights (ECHR).In "H. v. Norway", the European Commission did not exclude that "in certain circumstances" the fetus may enjoy "a certain protection under Article 2, first sentence".