Dear Deputy,
We are Academics for Reproductive Justice Ireland - a group of 40+ academics who research and advocate towards advancing reproductive freedom across the island of Ireland, and globally. As you may be aware, on Wednesday 13 May, a Bill to amend the Health (Regulation of Termination of Pregnancy) Act will pass through the Dáil. We note that these amendments broadly reflect the legal recommendations as advised in the Independent Review into the Operation of the Health Act (The O’Shea Report).[1]
Firstly, we ask that you support the progression of this Bill to the third stage - removing barriers to accessing safe reproductive healthcare.
We would also like to make the following comments relating to the amendments in this Bill:
Amendment 2: We believe that one medical practitioner is sufficient.
Amendment 3 (a) (1): We agree with the statement related to the diagnosis of a “fatal condition affecting the foetus” and we would recommend going further to remove “fatal” from this categorisation.
Amendment 4: We advocate that this section be removed in its entirety. All medical guidelines are updated on a regular basis by clinical experts – this is a policy issue and should not be included in legislation.
Amendment 5: We advocate that the three-day-wait be removed from legislation in its entirety.
Amendment 6: This amendment replaces Section 23 but still leaves medical practitioners and other providers of abortion open to the possibility of criminalisation. We advocate for the full removal of Section 23 with no replacement.
Amendment 7: We advocate extending the legal duty to cover non-medical staff and broadening it beyond medical emergencies to encompass all forms of care.
Amendment 8: We recommend further review of the legislation following three years.
Studies show that a lack of clarity on the criminal context of abortion hampers clinical decision-making, with negative consequences for birthing people.[2] In 2019, abortion provision was decriminalised in Northern Ireland and has created favourable professional conditions for the development and implementation of abortion services within the HSC.[3]
According to the World Health Organisation, “mandatory waiting periods can have the effect of delaying care, which can jeopardise women’s ability to access safe, legal abortion services and demeans women as competent decision-makers.”[4] The complete removal of the three-day-waiting period would bring Ireland in line WHO recommendations and with other European countries such as Luxembourg (2025) and the Netherlands (2021) who have recently removed mandatory waiting periods – while France have introduced a constitutional right to abortion care (2024).
Additionally, the full removal of the three-day-waiting period would also reduce the economic and workload burden on GP practices. A new national analysis by the Irish College of General Practitioners shows many patients cannot register with a GP as practices are closed to new patients, and that patients face delays in securing appointments.[5] Since the repeal of the Eighth Amendment, an average of 240 women travel from Ireland to the UK each year for abortion care.[6]. These journeys are mostly made due to a fatal foetal diagnosis or delays in care following the three day waiting period. Removing the restrictive criteria in determining a “fatal foetal anomaly” will empower medical practitioners to provide more informed, empathetic and professional care to birthing people – receiving the healthcare they need at home.[7]
Yours sincerely,
Dr. Sahar Ahmed, Technological University Dublin
Dr. James Beirne, Maynooth University
Jane Buggle, Institute of Art, Design and Technology, Dún Laoghaire (IADT)
Dr. Maria Butler, University College Dublin
Associate Professor Erika Biagini, Dublin City University
Dr. Sarah-Anne Buckley, University of Galway
Anna Carnegie, King’s College London
Dr. Arpita Chakraborty, Dublin City University
Dr. Dyuti Chakravarty, University College Cork
Zoë Coleman, Independent Researcher
Dr. Deirdre Niamh Duffy, Lancaster University
Dr. Jessamyn Fairfield, University of Galway
Elaine Feeney, University of Galway
Dr. Camilla Fitzsimons, Maynooth University
Dr. Kusumika Ghosh, Dublin City University
Dr. Lorraine Grimes, Independent Researcher
Associate Professor Miriam Haughton, University of Galway
Dr. Sinéad Kennedy, Maynooth University
Dr. Tina Kinsella, Institute of Art, Design and Technology, Dún Laoghaire (IADT)
Dr. Mary McAuliffe, University College Dublin
Dr. Emer McHugh, Queen’s University Belfast
Dr. Joanna Mishtal, Lehigh University - College of Health, USA
Dr. Anne Mulhall, University College Dublin
Mary Nevin, Trinity College Dublin
Dr. Maeve O'Brien, Independent Researcher
Dr. Aileen O’Carroll, Maynooth University
Dr. Theresa O’Keefe, University College Cork
Dr. Aideen O'Shaughnessy, University of Lincoln
Professor Saoirse Nic Gabhainn, University of Galway
Rashmi Guha Ray, University College Dublin
Dr. Valeria Resta, Dublin City University
Associate Professor Paola Rivetti, Dublin City University
If you would like to add your signature to this letter, please do so here.
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[1] Ms. Marie O’Shea, BL. The Independent Review of the Operation of the Health (Regulation of Termination of Pregnancy) Act 2018 https://www.gov.ie/en/department-of-health/publications/the-independent-review-of-the-operation-of-the-health-regulation-of-termination-of-pregnancy-act-2018/
[2] Rowlands S, Thomas K. Mandatory Waiting Periods Before Abortion and Sterilization: Theory and Practice. Int J Womens Health. 2020 Jul 31;12:577-586. https://doi:10.2147/IJWH.S257178. PMID: 32801935; PMCID: PMC7402852.
[3] Bloomer F, Kavanagh J, Morgan L, et al Abortion provision in Northern Ireland: the views of health professionals working in obstetrics and gynaecology units BMJ Sexual & Reproductive Health 2022;48:35-40 10.1136/bmjsrh-2020-200959
[4] World Health Organization (2025). Abortion care guideline: supplementary material 1: evidence-to-decision frameworks for the law and policy recommendations, 2nd ed. World Health Organization. https://doi.org/10.2471/B09494.
[5] Irish College of General Practitioners, (2025) Strengthening the Future of GP Care in Ireland, https://www.irishcollegeofgps.ie/Portals/0/Explore%20the%20College/About%20Us/Advocacy/Submissions/Strengthening%20the%20future%202025.pdf
[6] Abortion Support Network, 2025 Impact Report, https://www.asn.org.uk/wp-content/uploads/2025/12/2025-impact-report.pdf
[7] Grimes, L, et al., ‘Still travelling’: Access to abortion post-12 weeks gestation in Ireland, Women's Studies International Forum, Volume 98, 2023, 102709, ISSN 0277-5395, https://doi.org/10.1016/j.wsif.2023.102709.