Abstract
In this article I examine the paradoxical nature of abortion developments in three jurisdictions and find that reproductive freedom is a more elusive goal in the United States where abortion has been elevated to a qualified right, than in England or Victoria where nineteenth century criminal statutes have been modified but not repealed. Abortion is now a moral scapegoat in the United States and it is difficult to predict if it will ever be resolved. Changes to law in the other two jurisdictions were less extreme and were shaped by a gradual change in attitudes towards abortion. Nevertheless, the laws in all three jurisdictions deny women full reproductive freedom and are founded on the assumption that women are not responsible moral beings. The repeal of all laws concerning abortion would be a stepping stone to re-framing moral questions about abortion and developing a distinctive feminine morality which attends to the needs of women.
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