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International Law

ECHR mandate on reproductive rights, especially Abortion



The European Convention on Human Rights, ratified in the year 1953, established the European Court of Human Rights to “ensure the observance of the engagements undertaken by the High Contracting Parties.”[1] The Convention, formerly known as the Convention for the Protection of Human Rights and Fundamental Freedoms, was enacted to protect the basic Human Rights of the people, by subsequent judicial enforcement through the European Court. In Europe, the statistics show that the number of deaths resulting from pregnancy has been far less than those in other continents. However, there are disparities within the countries of the continent.[2] Article 8 of the Convention deals with the Reproductive Rights and sexual health in quite a broad manner.[3] The ECtHR has ruled on issues of whether a Right to Abortion exists under Article 8[4] and whether the fetus has a right to life under Article 2[5].[6] The Court has ruled that Abortion is not a right under the Convention, and hence there is no resultant right to have[7] or practice[8]Abortion. However, in a landmark decision of P. and S. v. Poland, the Court explained that individually the states might decide the circumstances under which Abortion may be permitted.[9] With respect to the right to life of a fetus, the Court held that the fetus does not enjoy an ‘absolute right to life.’[10] However, the Court took a dicey approach in opining further that because pregnancy cannot be said to be entirely under the ambit of the ‘private life of the mother,’ the fetus does have rights under certain circumstances.[11] Thus, it is evident that the Court was unwilling to “come off the fence” to advance the laws related to Abortion.[12]

From the year 2007 onwards, Article 8 has been interpreted in a procedural manner such that it is not just the state’s obligation to ensure that these rights are not violated, but also, that the state takes some ‘positive action’ to respect such rights.[13] This affirmative action arises in two situations- the first is where the state action ensures that these rights are respected and the second that the state has an incumbent duty to protect individuals from breach of such rights.[14] A pertinent example of the first situation would be the case of R.R. v. Poland[15], wherein the Court held it to be a failure on the part of the state of Poland when the hospitals denied the applicant an abortion, especially when the risky pregnancy fell under the ambit of Abortion under the Polish Law.[16] The second situation can be illustrated through the landmark case of A.B. and C. v. Ireland[17] where the European Court held in favor of procedural right under Article 8 that imposes a duty on the state to provide useful and accessible procedures that allow a woman to establish her right to a lawful abortion in Ireland.[18] Over the years many case studies suggesting that the European Court adopts a procedural approach towards the abortion rights to satisfy its political leanings[19], to serve the progressives and the conservatives alike, have come up, and looking at the trajectory of these case laws along with the regional disparity in statutes related to Abortion, the relevance of such case studies cannot be disputed.

As LiiriOja& Alicia Ely Yamin rightly opine – Disputed citizenship of women from the earlier era to the non-cognizance of reproductive rights as Human Rights, Europe has been the torch-bearer of the stereotypes associated with women.[20] It was not until the adoption of the 1953 Convention of Europe when the role of women started changing with respect to citizenship rights and reproductive rights too. The Court played the pre-inscribed stereotypes and flawed conceptions of gender in the garb of such progressive case laws. The whole idea of Article 8 under which the reproductive rights are adjudged, limit the area of women’s sexualities and reproductive freedom only to the ‘Private Sphere.’ This approach of segregating fundamental human rights into a private sphere contributes to the public-private debate as brought to light by Katherine MacKinnon.[21]Patricia Londoño finds such an approach extremely problematic for two reasons. Firstly because restricting reproductive rights to a private sphere contributes to the structural problem of the violence, abuse, and mental traumas experienced by women within their own families for adopting adoption over rearing the child. Secondly, such an approach also absolves the state to take concrete steps for the advancement of reproductive rights. Thereby making Abortion and reproduction a ‘private’ issue in which the state has no say.[22]

Both the landmark cases of R.R. v. Poland[23] and P. & S. v. Poland[24] have been adjudged by the Court in the sense of pity for the suffering that the woman is going through. This narrative completely ignores the conscious choice of women to have non-reproductive sex. The Court prescribes a paternalistic approach to the states concerning the procedural lapses in hospitals, thereby reinforcing the ideological stereotypes denying women any agency over their bodies.[25] With the lack of uniform laws on reproductive rights and Abortion per se, conscientious objection is now a common phenomenon wherein healthcare providers, or institutions refuse to provide reproductive health care services based on their religious or moral beliefs.[26] While religious beliefs are common, moral beliefs operate on a much broader stratum, especially in Poland and Italy, with ‘Nationalist’ and ‘Pronatalist’ beliefs being the most common not just historically but at present as well. The nationalist or pronatalist beliefs blame women for ‘irrational non-reproduction,’ which contributes to the narrative of such women being anti-nationalists because they are restricting higher fertility, which is required to ‘save the nation.’ This reproductive rhetoric has time and again comes in the way of an absence of set laws that advance women’s reproductive rights, including abortion ban.[27] Wanda Nowicka, a feminist activist, specializing in reproductive and health rights from Poland, opines that Europe does not have concrete legislation on reproductive rights and Abortion and instead invests in these areas through development aids. Her study concludes this lack of legislation, not a willful abstention but rather an indeterminacy to understand the issues around gender equality in the continent. Major laws in Europe revolve around the concept of equal pay as the only determinant of fundamental human rights of women. Gender-based discrimination and hence reproductive rights are not considered as human rights as such.[28]

[1] Former Article 19 of the ECHR.

[2] Id. at 14.


[4] Silva Monteiro Martins Ribeiro v. Portugal [GC], no. 16471/02, ECtHR 2004; P. and S. v. Poland, no. 57375/08, ECtHR 2013.

[5] Vo v France [GC], no. 53924/00, §80, ECtHR 2004.

[6]<> accessed on 03.07.19.

[7] Silva Monteiro Martins Ribeiro v. Portugal [GC], no. 16471/02, ECtHR 2004.

[8] Jean-Jacques Amy v. Belgium, no. 11684/85, EcmHR 1988.

[9] P. and S. v. Poland, no. 57375/08, ECtHR 2013.

[10] X v United Kingdom, no.8416/79, ECmHR 1980.

[11] Vo v France [GC], no. 53924/00, §80, ECtHR 2004.

[12] Joanna N Erdman, ‘Procedural abortion rights: Ireland and the European Court of Human Rights’, Reproductive Health Matters, Vol. 22, No. 44, Using the law and the courts (November 2014), pp. 22-30 <> accessed on 03.07.19.

[13]<> accessed on 03.07.19.

[14] Jacobs, White &Ovey, ‘the European Convention on Human Rights’, Oxford University Press, 4th edition, 2010, p. 243.

[15] R.R. v. Poland, Application No. 27617/04, Eur. Ct. H.R. (2011).

[16] Id. at 23.

[17] A, B, and C v. Ireland, [2010] E.C.H.R. 2032, Eur. Ct. H.R.

[18] Id. at 23.

[19] Id. at 23.

[20]LiiriOja& Alicia Ely Yamin, ‘“Woman” In The European Human Rights System: How Is The Reproductive Rights Jurisprudence Of The European Court Of Human Rights Constructing Narratives Of Women’s Citizenship?’, Columbia Journal of Gender and Law. <> accessed on 03.07.19.

[21] Ruth Gavison, ‘Feminism and the Public/Private Distinction’, Stanford Law Review Vol. 45, No. 1 (Nov., 1992), pp. 1-45 (45 pages)

[22] Id. at 31.

[23] Id. at 26.

[24] Id. at 20.

[25] Id. at 31.

[26] Christina Zampas, Ximena Andion-Ibanez, ‘Conscientious objection to sexual and reproductive health services: international human rights standards and European law and practice’, European journal of Health Law 2012. <> accessed on 03.07.19.

[27] JOANNA MISHTAL, ‘Reproductive Governance in the New Europe: Competing Visions of Morality, Sovereignty and Supranational Policy’, Anthropological Journal of European Cultures, Vol. 23, No. 1, THEMATIC FOCUS: Culture, Power and Policy in the New Europe (2014), pp. 59-76, < > accessed on 04.07.19

[28] Wanda Nowicka, ‘Sexual and reproductive rights and the human rights agenda: controversial and contested’, Reproductive Health Matters, Vol. 19, No. 38, Repoliticising sexual and reproductive health and rights (November 2011), pp. 119-128.<> Accessed on 04.07.19.

'The Author is a fourth year law student at Jindal Global Law School, India with a keen interest in International Laws and Women Rights.

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International Norms On Fair Hearing: The Case of US, UK and India



Fair hearing and its elements have been a hotly contested issue in administrative law. The right to fair hearing has traditionally been an indispensable aspect of the rules of natural justice. Broadly, the right to a fair hearing contains of several elements including but not limited to the right to a free and fair public hearing, the right to an independent and impartial tribunal and the right to present at an oral hearing. However, while fair hearing norms originates in the Articles 14 and 21 of the constitution in India, USA and UK trace it back to the 5th Amendment of the US Constitution[1] and Section 6 of the European Convention on Human Rights[2] respectively. Thus, the elements of fair hearing in the United States of America, the United Kingdom and India differs owing to these constitutional variations. These differences then evolve owing to diverse judicial interpretations which are based on different factors including expense, time and the need to avoid unduly binding administrative law making.

Despite these differences, fair hearing remains an important requirement in the process of administrative adjudication and ensures that every person being affected by a decision is granted a hearing before he suffers detriment. Thus, it is important that fair hearing remains an internationally recognised civil right while leaving significant discretion to individual states to adopt different procedural norms for practical demand.

This paper aims to understand the elements of fair hearing in three jurisdictions, namely US, UK and India. Accordingly, it first briefly traces the origins of the concept of fair hearing in administrative law and then narrows it down to understanding the evolution of the right in the three countries. Second, the paper makes a detailed scrutiny of the different elements of fair hearing in US, UK and India, observing the similarities and the differences. This involves exploring the judgments and legislative norms laid down in the three countries in this regard. Lastly, it specifically examines the effectiveness of the Indian notion of fair hearing in addressing administrative issues and ponders over the need to borrow from US and UK jurisdictions in this regard.

It concludes by reemphasising the importance of the right to fair hearing and how the differences in the fair hearing frameworks of the three countries points to different administrative demands and patterns.


The norms of natural justice were originally imposed in common law countries as minimum standards of fair decision making so as to ensure that bodies or persons ‘act judicially’. The natural justice norms were later differentiated into two rules: the rule against bias and the right to a fair hearing. However, while European nations focused more on non-procedural aspects such as jurisdiction and correct legal reasoning, the US Supreme Court insisted on understanding fair hearing norms as ‘the essence of the scheme of ordered liberty’[3]. This is difference is elaborated as follows-

The initial academic discussion on fair hearing in the US centred on due process norms. For instance, the courts in Crowell v. Benson[4] and Ohio Valley Water Co.[5] ensured that due process norms imposed traditional procedural restrictions as well as absolute limits on the powers of administrative bodies. On the other hand, the Human Rights Act 1998[6] in UK gives effect to the Article 6 of the European Convention on Human Rights which declares the norms for a fair hearing. The elements of fair hearing in UK originating from Article 6 of ECHR allow tribunals to have considerable discretion in conducting trials and admitting evidences. However, they are expected to uphold “natural justice” norms especially when taking decisions that directly affect the “legitimate expectations” of a government body[7].  

The Indian administrative law assumes audi alteram partem or the right not to be condemned unheard to be an essential constituent of natural justice norms. Accordingly, the right to fair hearing, although not explicitly legislated on, has been firmly grounded in Articles 14 and 21 of the Indian Constitution. Further, fair hearing norms involve several different rights recognised through various judicial precedents i.e. right to notice, right to present case and evidence, reasoned decision etc. The norms have also provided for certain exceptions in the administrative law which form legal grounds for avoiding the application of fair hearing norms. However, there is no straightjacket formula for its determination and it depends on the particular circumstances of an administrative law case[8].

Thus, it may be argued that the fair hearing norms of the three countries have had different origins thus different substantial outputs. For instance, while English and Indian laws do not have general due process requirements for all governmental action affecting private citizens, it is quite the contrary in the US law. Nonetheless, fair hearing maintains its universal applicability in ‘laying duty upon everyone who decides everything’. 


Owing to different origins and administrative law advancements, the fair hearing norms of UK, US and India substantially differ from one another. For instance, the US norms demand that a party not only be given opportunity to present evidence, but allowed to know the claims of opposing party as well as meet them. Those who contest government claims in a quasi-judicial proceeding are expected to be informed of government proposals and heard on them before the final order[9]. Similarly, the US law does not guarantee a right to oral hearing under fair hearing norms and decides upon it on a case to case basis.

More importantly, the Constitution of the US, in its 5th Amendment, also does not guarantee a trial type hearing in every governmental infraction of private rights[10]. For these reasons, administrative bodies such as the Civil Rights Commission do not accord the right to confront or cross examine witnesses as they only serve as investigative bodies and make no adjudications.

The present norms on fair hearing in United Kingdom may be traced to the judgment in Ridge v. Baldwin[11] which abandoned analysing the administrative and adjudicatory roles of decision making bodies and turned to the precise content of the complainants’ rights. The judgment declared that the applicant in an administrative law case may rely on prior legitimate expectations that the law will fulfil in the absence of countervailing considerations. This expectation may arise out of any prior course of conduct by the executive bodies in regard to the applicant’s case. The adjudicatory body will then have to determine the exact content of the right through these legitimate expectations[12]. However, the ECHR which is the basis for the UK fair hearing norms lay down three participation principles that are to be necessarily complied with. These are the principle of respectful treatment, the ‘equality of arms’ norm and the adversarial principle.

In India, the concept of fair hearing is a fairly elastic one and may not be contained within any precise definition. Thus, there are no indispensable standards of reasonableness that have to be complied with except that the conscience of the court should be satisfied that the person who will be affected by a decision has had a fair chance of convincing the particular authority[13]. However, the Supreme Court of India has also clarified that the principles of natural justice demand that a minimum fair procedure be always followed. This minimum fair procedure is, however, for the court to determine based on the particular facts and circumstances of the case. Nonetheless, the court has through judgments such as Maneka Gandhi v. Union of India[14] espoused fairness jurisprudence in regard to the civil rights of a citizen. Accordingly, some liberal norms for fair hearing that the judiciary has laid down over the years include: decision maker to be above bias, need to state reasons etc.

The United Kingdom, the United States and India all fall in the category of commonwealth nations. However, their legal regimes and fair hearing notions are marked by wide differences. For instance, while the UK law focuses on a limited arena of the norms of natural justice, the US law is embedded in the concept of procedural due process[15]. However, while US makes use of the right to notice and right to be heard to further the basic constitutional guarantees of the protection of life, liberty and property, UK also uses the ‘margin of appreciation’ in ECHR norms to guarantee the same rights[16].

Further, the right to fair hearing in UK is expressly limited by several factors ranging from merits of a case to morals and national security. On the other hand, although there exist no identifiable limits on due process and fair hearing norms in US, the identified purposes of procedural due process and rule of law serve as implicit limits[17].

On a comparison between Britain and India, while Britain has experimented with a right based approach before returning to the basic principle of fairness as a core constituent of fair hearing issues, India has merely made sporadic attempts to disregard statutory stipulations in order to preserve fairness and natural justice procedures.

Additionally, the Indian Supreme Court has stated that the notwithstanding any finality clauses in any act, Articles 136 and 226 allow the judiciary to review a law for violation of natural justice norms[18]. This is in contrast with US law which excludes certain congressional norms from the purview of due process requirements and judicial review. The US also has relaxed norms for attracting fair hearing norms as compared to India. For instance, while the US law allows for its non-application only in non-immediate matters or during subjective applications of the act, the Indian Supreme Court has insisted that audi alteram partem may only be used only in the instances of the violation of liberty or property causing grave injustices[19].

Therefore, it may be conclusively argued that the laws on fair hearing in the US, UK and India are based on entirely different perceptions and have evolved accordingly, thus the vast differences.


Notwithstanding the differences between the fair hearing norms in the US, UK and India, there are startling similarities owing to their similar common law origins. The fair hearing norms in all the three countries have constantly strengthened and have expanded the substantive idea of fairness so as to achieve fairer outcomes. This is largely because of the natural law entitlements of individuals that common law traditions have endowed upon the masses. Further, all common law jurisdictions share social policy, tradition and elaborated analogies in various forms. Thus, the right of a man to be given fair opportunity to be heard on what has been alleged against him is a universal principle in all common law jurisdictions and hence, in all three countries, namely US, UK and India[20].

Similarly, common law countries as well as nations falling under the jurisdiction of ECHR i.e. UK, allow quasi-judicial agencies to not completely comply with all the norms of procedural fairness if the affected person has any recourse to a further hearing or appeal. On the question of exceptions to the natural justice norms too, UK and India both use similar factors of time, place and apprehended danger etc. to ascertain their application. However, all the applicable exceptions are merely circumstantial and not conclusive[21].

Further, another common law norm adopted by all the three countries is the requirement for adjudicating bodies to provide reasons for the decisions they make. In India, duty to provide reasons as a requirement of fair hearing norms, even in the absence of statutory provisions, is a judge-made law[22]. In UK, the section 12 of the Tribunals and Inquiries Act, 1946 requires them to provide with reasons only when the parties ask for them. However, there is now a judicial trend for transparency that mandates the administrative authorities to provide reasons in all circumstances[23]. Finally, in US too, Section 8(b) of the Administrative Procedure Act, 1946 mandates administrative agencies to give reasons for their decisions.

Another important similarity between the fair hearing norms is the principle of ‘one who decides must hear’. Accordingly, UK’s House of Lords in Arlidge[24], the Indian judiciary in Nageshwar Rao[25] and the US Supreme Court in Morgan v. United States[26] have made clear that the duty to decide a case cannot be performed by someone who has not heard the arguments or evidence. Thus, unless it unduly complicates administrative proceedings, one administrative body should decide a case from the beginning to the end in all the three countries.

Additionally, the principle of post decisional hearing has been considered to be an exception in all common law jurisdictions, especially US and India. The Indian Supreme Court in H. L. Trehan[27] has clarified that post decisional hearing should not subserve the norms of natural justice and it may only be used in exceptions such as deprivation of life and liberty etc. Similarly, in US, due process requires that fear hearing is ensured with promptitude. Thus, post decisional hearing is allowed only in the case of extreme violations of public interest of impracticability and emergency.

Most importantly, in all three countries, principles of natural justice and fair hearing norms are meant to supplement and not alter the law. They are an integral part of the concept of good governance norms and hence, any claim to exclude any particular administrative hearing from the purview of fair hearing norms imposes the burden to prove so on the one demanding such exclusion[28].

Thus, it may be concluded that the UK, US and India respect certain elements of fair hearing as absolutely essential and have incorporated them into the law in different forms. The three countries owe these similarities to their common law origins which have retained some traditions and practices for many centuries.


In India, there is no statutory enactment on the minimum procedures that administrative agencies have to comply with. The vigilance of the judiciary has thus, become the best safeguard for fair hearing and procedural fairness in extremely complicated administrative law cases. This is accompanied by constitutional provisions in Article 311 of the Indian Constitution that provides the right to hearing of a civil servant when he is removed, dismissed or reduction in rank. Accordingly, the person affected by the violation of his civil rights may use constitutional provisions or the concerned statue to argue principles of natural justice without invoking any prejudice or civil consequence. Further, the constitutional affirmation of the natural justice norms by the judiciary has ensured that they are read into every administrative case, subject to exclusions. As the Indian administrative law is largely judge-made, the exclusions to natural justice norms i.e. confidentiality, impracticability etc., have also been developed through judicial precedents only[29].

Additionally, Indian courts have made clear their stance on the effect of any administrative law decision made in violation of the rule of bias. The aggrieved individual or body has the opportunity to accept such decision and it may not be necessarily void. This acceptance of the bias will be deemed to have been done if the party has the conscious knowledge of such a bias[30].

This analysis makes it clear that the Indian administrative law has various elements of fair hearing that are unique to the nation in different ways. There are little determinable standards on what fair hearing constitutes and judiciary has preferred to use higher standards in cases of more serious consequences. However, all the fair hearing norms are designed to prevent authorities from doing injustice[31].

The above analysis indicates that the Indian administrative law has its separate and unique needs and the judicial precedents on fair hearings are comprehensive enough to adequately address them. However, the judiciary needs to ensure it keeps certain important principles on fair hearing in mind. For instance, the inherent human dignity of persons before the tribunals be respected, they be entitled to consult and represented by a legal representative and provided adequate opportunity to present their case, among others. 


The elements of fair hearing in the United Kingdom, the United States and India have originated and evolved according to the individual administrative needs of the three nations. For instance, while US law solely insists on due process norms based in the 5th amendment, the UK and Indian laws are equally focused on technical administrative requirements such as the legal eligibility of a body to listen a case. The Indian administrative law is in its infant stage and thus has witnessed the judiciary espousing hitherto unused natural justice norms. However, these fair hearing norms have also been borrowed from and are a combination of the common law traditions which encompasses the US and UK law.

The common law origins of the three countries’ fair hearing norms have ensured that these reverenced certain principles irrespective of jurisdictional constraints. Thus, there is a stark similarity between them in terms of the post decisional hearings, the deciding body and the need to provide with adequate reasons in relation to the decision rendered. This, in turn, has ensured a consistency in terms of the importance given to the fair hearing norms and the application of administrative law in the three nations.  

Thus, it may be argued that the fair hearing norms in the three countries are marked by many similarities. However, the different nature of the jurisdictions under which the authority is usually conferred to the administrative bodies in the three nations is varied, thus leading to many differences as well. Therefore, it is important that while they respect the common law traditions that have been a part of their legal cultures, the judiciary of the three nations should render administrative decisions while taking into account the character of the rights of the person affected. This will allow the administrative law in these nations to progress as well as retain its core elements.

[1] The Constitution of the United States, 5th Amendment

[2] European Convention on Human Rights, 1953

[3] T. Koompans, ‘Natural Justice Rediviva? The Right to a fair hearing in European Law’ (1992) 39(1) NILR < :> accessed 7 May 2021

[4] Ohio Bell Tel. Co. v. Public Utils Commn, 301 U.S. 292 (1937)

[5] 253 U.S. 287 (1920)

[6] Human Rights Act, 1998

[7] H Davis, ‘The Right to a Fair Hearing’ (Bournemouth 2014) <> accessed 13 May 2021

[8] D.D. Basu, Commentary on the Constitution of India (9th ed., vol 1, LexisNexis India 2014)

[9] Morgan v. United States, 304 U.S. 1 (1938)

[10] Cafeteria & Restaurant Workers v. McElroy367 U.S. 886 (1961)

[11] Ridge v. Baldwin [1964] AC 40

[12] Swati Jhaweri, ‘Right to a fair hearing in administrative law cases’, The Max Planck Encyclopedia of Comparative Constitutional Law (Oct 2016) < :> accessed 10 May 2021

[13] Ibid 5

[14] Maneka Gandhi v. Union of India, (1978) 1 SCC 248

[15] Nathaniel Nathanson, ‘The Right to Fair Hearing in Indian, English and American Administrative Law’ (1959) 4(1) JILI <> accessed 10 May 2021

[16] Ola Johan Settem, Applications of the Fair Hearing Norm in ECHR Article 6(1) Proceedings, (Springer International Publishing Switzerland 2016)

[17] Edward Rubin, ‘Due Process and the Administrative State’ (1984) 72(6) CLR <> accessed 2 May 2021

[18] Lydia Kerketta, ‘Audi Alteram Partem: The right to a fair hearing’ (Legal Services India) <> accessed 14 May 2021

[19] Ibid 5

[20] Ibid 9

[21] Ibid 12

[22] M.J. Sivani v. State of Karnataka, (1995) 6 SCC 289

[23] S A de Smith, ‘The Right to a Hearing in English Administrative Law’ (1955) 68 Harv L Rev 569

[24] Local Government Board v. Arlidge [1915] AC 120 [HL]

[25] Gullapalli Nageshwar Rao v. A.P. State Transport Corpn., 1959 Supp (1) SCR 319

[26] Ibid 6

[27] H.L. Trehan v. Union of India, (1989) 1 SCC 764

[28] I. P. Massey, Administrative Law (8th ed. Eastern Book Company, 2012)

[29] Ibid 5

[30] Ibid 25

[31] P. Leelakrishnan, Mini S. ‘Procedural Fairness in Administrative Decision Making’ (2017) 59(4) JILI < :> accessed 6 May 2021

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