title: Commissioner of Police v. Modebe, 1980.
abstract: The accused was charged with violation of Section 233 of the Nigerian Penal Code by administering medical treatment to a woman which caused a miscarriage resulting in her death.  The accused had treated a woman who had come to him after attempting to terminate her pregnancy; he had removed manually some of the septic remains of her fetus and then instructed her to go to a hospital, which she did not do.  The Court acquitted the accused, ruling that, in order to commit a crime under Section 233 of the Penal Code, a person must have the intention of causing the miscarriage, which was not shown here.
mesh_terms: D000024:Abortion, Illegal; D000028:Abortion, Induced; D000031:Abortion, Septic; D000349:Africa; D017954:Africa South of the Sahara; D000354:Africa, Western; D003906:Developing Countries; D004194:Disease; D005193:Family Planning Services; D007603:Jurisprudence; D009549:Nigeria; D011248:Pregnancy Complications; D013812:Therapeutics
keywords: Abortion, Illegal; Abortion, Induced--legal aspects; Abortion, Septic; Africa; Africa South Of The Sahara; Court Decision; Developing Countries; Diseases; English Speaking Africa; Family Planning; Fertility Control, Postconception; Nigeria; Pregnancy Complications; Treatment; Western Africa