Comparative study of fetal abuse in the Criminal System of England , United States and Iran

Abstract

Today, fetal health protection is more important than ever to health and legal actors. Fetal abuse is a term that has evolved with the advancement of medical science in recent decades and includes not only behaviors that result in abortion but also other intentional behaviors that cause harm other than abortion as well as behaviors. Which is mainly due to the negligence or carelessness of the person carrying the fetus or others. This article uses analytical-descriptive method and using library resources to review and compare the criminal laws of Iran, USA and the United Kingdom in the field of fetal abuse. Regarding intentional fetal abuse, especially abortion, most of the world's penal systems, especially the system The criminal law of the three countries discussed in this study has developed several laws, but the embryo of harassment due to negligence or carelessness has received less attention from lawmakers. The findings show that in some US states, such as South Carolina, this issue has received more attention. In the penal system of the United Kingdom and Iran, the issue of fetal abuse due to negligence has not received much attention, although in Iran, the law on how to donate embryos to infertile couples has dealt with such behaviors to a small extent