Dr. Mhlanga
Chief Director Maternal, Child and Women’s Health
Private Bag x828
Pretoria 001

Dear Dr. Mhlanga,
At the very outset we would like to remark on the facts that:
Every Abortion, legal or illegal, causes the death of a totally innocent, helpless unborn child.
The legalisation of abortion on any pretext whatsoever, including abortion for rape, incest, unlawful carnal knowledge, handicapped unborn children, where the mother is suffering from a psychiatric illness, and in those exceptionally rare cases to save the life of the mother, always involves the deliberate killing of an innocent unborn child and is intrinsically evil.
The provision of abortion on request on the pretext of allowing mothers to kill their children in relative safety and to reduce the physical consequences, including death, sometimes associated with illegal abortions, loses sight of the fact that irrespective of whether the abortion is performed legally or not a helpless pre-born child is deliberately killed. It is totally irrelevant to the child whether he or she was killed legally or illegally.
It is not reasonable to make comments on the proposed Amendments on the Choice on Termination of Pregnancy Act without reference to the Act itself any more than it would have been reasonable to make comments on amendments to consolidate, advance and reinforce the very worst of the previous Apartheid Laws without reference to and criticism of those evil Laws themselves.
The only reason that Pro-Life makes any comments whatsoever on the wicked Choice on Termination of Pregnancy Act, or the proposed Amendments to this murderous law is to do the following:
To register once again before men and God our total and unwavering opposition to this law.
To again inform the Government of our implacable opposition to the killing of innocent pre-born babies and of our determination to protect the lives of these children.
In the hope that the Government will insist that the medical and nursing professions return to their absolute and unconditional respect and reverence for human life.
To remind the Government and its various spokespersons that birth is simply an event along the continuum of life from conception to death and that love for children and the protection of them must also be applied to children in the womb as well as to those who have already been born.
To remind the Government that "Women’s Rights" which allow women to kill their unborn children are a wicked perversion of the meaning of "rights" which afford those women a right to "choose to kill".
To record that we anticipate and pray for the day when those responsible for the wholesale murder of unborn children will be brought to justice before a new tribunal in the same way as war criminals were dealt with at Nuremberg.
In the hope that God in His infinite mercy will enlighten the minds and souls of those responsible for the slaughter of unborn children.
With the prayer that God, the author of life, because of the faithfulness and witness of those who oppose the spilling of the blood of totally innocent, helpless, unborn children brought about by the Choice on Termination of Pregnancy Act, as well as the previous Abortion and Sterilisation Act of 1975, will not further inflict this country with just and most terrible punishments.
The mockery of requiring comments and representations against the regulations extending the killing of unborn children to be directed to the Chief Director of Maternal, Child and Women’s Health who is the author of these proposed amendments.
The proposed Amendments have been published without explanation of why the Government needs to introduce these Amendments, apart from the clearly understood enduring intention of the Government to consolidate, expand and reinforce this profoundly evil Legislation.

The Choice on Termination of Pregnancy Act (hereafter referred to as the Act) is primarily intended to facilitate the brutal slaughter of unborn children at the request of the mothers of these children. Its aim is to propagate and normalise child sacrifice as a "reproductive right" and as a method of birth control and of correcting "contraceptive failures".

The very title of the Act, namely the Choice on Termination of Pregnancy Act is the epitome of deceit. The normal termination of pregnancy is brought about by the delivery of a child. This Act has nothing to do with terminating pregnancy by safely delivering children but has everything to do with facilitating the killing of them. Its title is simply a gross obfuscation intended to disguise the intention of legally permitting women the "Choice" of killing their unborn babies. It has everything to do with brutally terminating the lives of unborn children. It has nothing to do with terminating pregnancy by the safe delivery of a child. It deprives unborn children of the most fundamental of all human rights, namely the right to life. Clearly without the right to life all other human rights are totally meaningless.

Since the introduction of this iniquitous Act in 1997 more that a quarter of a million unborn children have been slaughtered. Despite the vast scale of this war on the unborn the Government has consistently sought ways and means to expand abortion and to force doctors and nurses who refuse to stain their hands and souls with the blood of unborn children, to participate in this evil. To this end it has worked closely with organisations such as the "Reproductive Rights Alliance" which is a front organisation of Planned Parenthood and its other abortion fellow travellers such The Abortion Reform Action Group.

In fact Parliamentary Commissions of Enquiry have been organised, funded and controlled by the Reproductive Rights Alliance. In the past the State together with this organisation has limited and ignored pro-life submissions, petitions and evidence and has insulted, threatened and hectored pro-life spokespersons while simultaneously giving free reign or bestowing honours on those who plan, advocate, promote or who actually kill unborn children. Despite the past behaviour of the Government and its representatives and agents who were involved in this matter, we hope that the Government will not ignore this submission much in the way as it ignored overwhelming public opinion against abortion and threatened its own members of Parliament with expulsion unless they voted for this Act. We also hope that the Government will not insult or threaten those who hold the lives of unborn children to be sacrosanct as has been the case in the past. Despite the Government’s dismal record of organised violence against unborn children and its refusal to hear the cries of the innocent unborn children who are slaughtered and its refusal to heed Pro-Life’s pleas for their lives, we are duty bound by God Himself to once again advise the Government of its iniquity. We are all obliged to protect the lives of innocent children. We pray that the consciences of all those involved in overseeing this shocking sacrifice of children on the altar of "Choice", "sexual freedom", "Women’s Rights" and "Reproductive Rights", will be touched by the mercy of God.

That this Government, and in particular this Director and his Directorate of Maternal, Child and Women’s Health simultaneously oversees, promotes and facilitates the killing of unborn children while bearing responsibility for the health of children after birth reveals hypocrisy, and conflict of interest. This Directorate, as far as children are concerned, is charged with the care of children after birth but oversees and supports their killing before birth. It is impossible for an ordinary person, who by the use of reason and simple observation of biological facts, is fully aware of the humanity of the unborn child, let alone a qualified medical practitioner training in human embryology and genetics to understand this astonishing contradiction and conflict of interest.

The Director and his Directorate are also responsible for Maternal and Women’s Health. Abortions, besides being intentionally lethal for unborn children, are also dangerous for the mothers of these children and can and do cause the deaths of women who undergo abortions as well as being responsible for a large number of physical, mental, familial and social complications and sequelae. Not to mention the grave harm done to the souls of women who kill their children. Amongst the many known complications of induced abortion are cancer of the breast, sepsis; haemorrhage; perforated wombs; blood transfusions (with its attendant risks of HIV, hepatitis and other virus transmission); future infertility, and the post-abortion syndrome. Accordingly, it is astonishing that that the Government does not publish information regarding the relationship of these complications to legal abortions.

Prior to the introduction of abortion on request it was claimed by the government and other members of the abortion lobby, that hundreds of women died each year as a result of illegal or "back street" abortions. It was usually implied that harm was done to women because abortions were performed on them by unskilled and untrained persons. In this connection it is noted that the proposed amendments wish to push the performance of abortions down the skills pyramid by allowing nurses to perform them, thereby further jeopardising the lives and health of women who undergo them. The Government’s intention is to normalise abortion in "every street" in South Africa.

One of the reasons given by the Government for the legalisation of abortion on request was that it was concerned about the alleged 200,000 to 300,000 illegal "back-street" abortions being performed each year in South Africa, despite the fact that its own Epidemiological Reports published estimates that there were at most between 9,000 and 42,000 illegal abortions a year. Now in a climate of free access to abortion on request there have been about 250,000 legal abortions in the five years since the introduction of this law in 1997. Apart from the absolute horror of this killing, constituting the eradication of the total population of a large city, this number emphasizes the lies put out by the abortion lobby who claimed as many as 300,000 back-street abortions a year. These figures were advanced as a strong reason for the Government to allow women access to "safe Legal abortions" which would, so they claimed, eradicate unsafe illegal abortions. It must be noted that no abortions, including those performed legally, are totally without risk to the health and lives of women, but that most illegal abortions were performed and still continue to be performed by medically trained personnel. We must say once again that "safe legal abortions" are, and are intended to be, always lethal for unborn children. We note that in the performance of abortions in the third trimester of pregnancy, when the baby is able to survive outside of the womb of its mother, that these premature babies if delivered alive are neglected until they die. They are not afforded even the basic care given to wanted premature babies. This emphasizing that the true meaning and intent of "termination of pregnancy" is to kill the unwanted child.

We have not been able to find Government estimates of the numbers of illegal abortions nor have those who performed illegal abortions since the introduction of the Choice on Termination of Pregnancy Act and up to the present time been prosecuted although we note the new proposed amendments in this disgraceful situation.

We also note the widespread use of misoprostol (Cytotec) to procure abortions, despite the fact that its manufacturer does not recommend its use and that the Medicines Control Board has not approved its use for procuring abortions.

Concerning the Director’s responsibility for Child Health it must be stated that in performing abortions on young women, themselves classified as children in terms of the South African Law, the State eradicates evidence of Statutory Rape and Incest because there is no attempt to identify and to prosecute the males responsible for violating and impregnating underage females. Furthermore the Department of Health does not require that the corpses of the aborted babies be submitted for DNA typing in order to prove paternity and thereby to facilitate the identification and prosecution of those males who rape and otherwise sexually abuse underage females. This in appalling contradiction to the Government’s professed horror at the Sexual Abuse of Children.

We note that the proposed amendment to delegate authority for the designation of abortuaries to the Member of the Executive Council of a Province who is responsible for Health in that Province will result in varying standards for women undergoing abortions and the delegation of this matter to persons who may not be medically trained. We also see it as an attempt by the Central Government to dilute their responsibility and accountability for this matter.

The proposed amendment to allow all units providing 24 hours maternity services to perform abortions will turn facilities whose sole purpose was previously to efficiently care for unborn children and then to safely deliver them, into facilities which would also efficiently kill unborn children. A most astonishing and horrendous situation! A replacement of the Gospel of Life by the Culture of Death.

In conclusion we urge the Government:
To strike down the Choice on Termination of Pregnancy Act in its entirety and thereby to begin to restore respect for the sanctity of Human Life from conception to natural or accidental death.
To provide women who find themselves during pregnancy to be in serious difficulties with all the help needed to safely deliver and to care for their babies.
To prosecute those responsible for the statutory rape of minor females.
To ensure that males responsible for impregnating women be held financially accountable for the care of these women and for the support of their children.
To ensure that "the right to life" in our Constitution be applied to pre-born children.

Yours sincerely
Dr. Claude E. Newbury
M.B., B.Ch., D.T.M&H., D.O.H., D.P.H., M.F.G.P., D.C.H., D.A., M. Prax. Med.

Pro-Life South Africa
P.O. Box 229
Cresta 2118
[email protected]

27 June 2003