plaintiff. Magistrate Hiatt found the accused acted with intent to procure her own miscarriage and was satisfied beyond reasonable doubt that the offence under s 82 was made out; conviction established;...
Key principles
The terms 'miscarriage' and 'abortion' in s 82 of the Crimes Act 1900 should be read in their ordinary sense, informed by dictionary definitions, and apply to termination of...
For the purposes of s 82 the relevant mental element is an intention to 'procure her miscarriage'; whether a miscarriage actually occurs, or whether the foetus is viable, is not...
Section 33 of the Interpretation Act 1987 supports a purposive construction that promotes the object of the Act; construing 'miscarriage' to be limited to pre-viable pregnancies...
Issues before the court
Whether the statutory term 'miscarriage' in s 82 of the Crimes Act 1900 is limited to pre-viable pregnancy (i.e. generally under 20 weeks or under...
Whether proof of intention to procure miscarriage requires proof that the accused believed the act would, or could, actually produce a miscarriage...
Plain English Summary
A Local Court magistrate convicted a woman under s 82 of the Crimes Act 1900 for self-administering misoprostol with intent to procure her own miscarriage. The key legal question was whether 'miscarriage' in the statute is limited to pre-viable pregnancies. The magistrate held that ordinary dictionary meanings apply but, applying the purposive construction required by the Interpretation Act 1987 s 33, concluded the statute protects the foetus across all stages of pregnancy; viability is not a limiting legal factor. The relevant mens rea is intention to procure miscarriage at the time of administering the drug; whether miscarriage actually occurs is not decisive. The magistrate found the intention proved and convicted, reserving sentence.
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Deep Dive
1,819 words · generated 21/08/2026
What happened
This is a Local Court (Blacktown) summary hearing decision in Director of Public Prosecutions (NSW) v Lasuladu [2017] NSWLC 11, delivered by Magistrate G Hiatt on 5 July 2017. The accused, Linda Khamis Lasuladu, was charged under s 82 of the Crimes Act 1900 with unlawfully administering to herself a drug (misoprostol) with intent to procure her own miscarriage. The Crown tendered a brief of evidence by agreement, and the defence called a single expert witness, Dr Carol Portman (Obstetrician/Gynaecologist), to give evidence about the medical meanings of 'miscarriage' and 'abortion'.
Cited legislation
No linked legislation citations have been extracted yet.
Facts established by the tendered brief (accepted by the magistrate for the purpose of conviction and sentence) include: the accused was pregnant and, at about 26 weeks, sought termination but was refused by clinics; she contacted a person ('Patrick') who supplied misoprostol; on 2 September 2015 she received ten 200 mg misoprostol tablets; on 3 September 2015 she took six tablets (two orally, four vaginally); she became unwell, was taken to Blacktown Hospital, presented the blister pack, foetal distress was found, and an emergency caesarean section was performed and the child was born.
The parties agreed the first two elements of s 82 (that the accused was pregnant and unlawfully administered a drug to herself) were made out. The trial concentrated on the third element: did the accused intend to procure her miscarriage? The defence contended that 'miscarriage' in s 82 should be read in accordance with contemporary medical definitions that confine miscarriage to pre-viable pregnancy (often described as under 20 weeks or under 400 grams), whereas the Crown argued that the statutory words were broader and the relevant inquiry was the accused's intention irrespective of viability. The magistrate admitted the expert's evidence only in a narrow sense (to provide medical context) and ultimately rejected a legal limitation to pre-viability. The magistrate found the intention proved beyond reasonable doubt and convicted, reserving sentence.
Why the court decided this way
There are two linked legal questions the magistrate resolved:
What do the statutory words 'miscarriage' and 'abortion' mean in s 82 of the Crimes Act 1900?
Is the mens rea satisfied by the accused's intention to procure a miscarriage even if that intended outcome may not actually occur (or if the foetus is viable)?
Approach to statutory meaning
The magistrate began with the ordinary meaning of words, consulting standard dictionaries (Oxford English Dictionary, Macquarie Dictionary) as the parties had done (see the judgment's recitation of those definitions). He accepted that dictionary definitions are a proper starting point (the Crown relied on such authorities and on the general rule favouring ordinary meanings).
However, the magistrate did not stop at dictionary definitions. He applied a purposive approach under the Interpretation Act 1987 s 33: a construction that promotes the underlying purpose or object of the Act is to be preferred. The magistrate asked what Parliament's clear intent in enacting Division 12 (ss 82–84) was.
Purposive conclusion
The magistrate concluded that the object of Division 12 was to criminalise unlawful acts that procure termination of pregnancy, i.e. to protect foetuses across all stages from unlawful termination. Construing 'miscarriage' to be limited to pre-viability would create an anomalous result: unlawful procurement of termination would be criminal only at some stages but not others. The magistrate regarded this as an untenable reading inconsistent with parliamentary purpose and with s 33.
Mens rea and causation
The magistrate accepted the Crown's submission (and authorities cited, notably R v Spicer) that the crucial question is the actor's intention when performing the acts. Whether the act produces a miscarriage is not decisive; it is the intention to procure miscarriage that constitutes the mens rea. The magistrate also relied on authorities (R v Sood) cited for the proposition that the offence can be complete on administration or insertion of the drug.
Weighing medical evidence
The magistrate acknowledged Dr Portman's evidence that medically a 'miscarriage' is now generally used for pregnancy loss before viability (about 20 weeks). He accepted that the evidence was 'illuminating' medically but did not regard it as determinative of the legal meaning of the statutory term. He explicitly refused to adopt medical definitions as supplanting the statute's meaning when the purposive legislative reading pointed otherwise.
Conclusion
Combining ordinary meaning with purposive construction, and applying the mens rea principles, the magistrate found that s 82 covers unlawful termination at any stage of pregnancy and that the accused's acts and intent (ingesting and inserting misoprostol with instructions to induce termination) established the requisite intention to procure miscarriage beyond reasonable doubt. He therefore found the offence proved and proceeded to sentence submissions.
Before and after state of the law
Before this decision
The statutory wording of ss 82–84 has been on the books since 1900 and did not itself define 'miscarriage' or 'abortion'. There was a lack of binding authority in NSW on whether those terms were to be read as limited to pre-viability or extended to all stages of pregnancy for the purposes of the relevant offences. The decision cites earlier authorities on lawfulness of abortion in certain circumstances (CES v Superclinics; R v Wald), and principles about interpreting statutory words by ordinary meaning or purposively.
After this decision (within the Local Court context)
The decision stands at Local Court level as a binding outcome in that proceeding. It establishes, at least in this court's view, that for s 82 the statutory terms are not confined to the medical concept of miscarriage as pre-viability. It also applies the proposition that intent to procure is the operative mens rea and need not be tied to the eventual occurrence of a miscarriage.
Scope and limits
This is a Local Court decision (Magistrate's principal judgment). It is persuasive rather than authoritative binding precedent for higher courts. Higher courts may accept, refine, or reject its reasoning. The magistrate relied on established interpretive principles (Interpretation Act s 33; ordinary meaning as a starting point), and cited existing authorities for the mens rea point, so the reasoning sits within mainstream statutory interpretation and criminal-law mens rea doctrine.
Key passages with plain-English translation
Selected passages from the judgment and a plain-English rendering:
Judgment: "To the extent necessary I would conclude that those definitions apply to an offence under section 82 ..."
Translation: The court accepts dictionary meanings of 'miscarriage' and 'abortion' as useful starting points for interpreting s 82.
Judgment: "I am not of the view that the issues raised by the accused as to whether the foetus is pre-viable or viable has relevance in relation to the offence."
Translation: Whether the foetus could survive outside the womb (viability) is not a legal limit on the offence in s 82.
Judgment: "In my view the clear intent of the Parliament was ... protection for a foetus from the time of conception through all stages of pregnancy to the point of birth."
Translation: The court thinks the purpose of the criminal offences is to cover unlawful attempts to end pregnancy at any stage, so the statute must be read broadly in that sense.
Judgment: Quoting Pepsi Seven-Up and saying courts will refuse to admit evidence to override ordinary meaning.
Translation: The court is cautious about letting specialist medical definitions displace ordinary language and statutory purpose when interpreting the statute.
Judgment: "I am satisfied beyond reasonable doubt that the accused ... acted with intent to procure her own miscarriage..."
Translation: On the facts, the magistrate was convinced the accused intended to induce termination by taking misoprostol, and therefore the offence under s 82 was proved.
What fact patterns trigger this precedent
This Local Court decision is relevant where:
A person (in NSW) is charged under s 82 for self-administering a drug or using an instrument with the intent to procure miscarriage/abortion, and
The alleged conduct occurs at a stage of pregnancy that might be categorised as 'viable' under contemporary medical standards (i.e. after 20 weeks), and an issue is raised whether the statutory words should be limited to pre-viable pregnancy.
The decision flags that a court may treat 'miscarriage' and 'abortion' as covering termination at any stage and focus on the defendant's intent at the time of the act, rather than the stage of gestation, when considering the mental element of the offence.
How later courts have treated it
As a Local Court judgment, its persuasive effect depends on whether higher courts cite or adopt its reasoning. Within this judgment the magistrate relied on earlier higher-court authorities for interpretive and mens rea propositions (for instance, R v Spicer on intent and R v Sood on completion). To determine how later courts treated Lasuladu, one must search subsequent NSW and appellate decisions to see whether they cited it. The judgment itself does not report later treatment. Practitioners should verify subsequent citations in legal databases to determine whether superior courts have followed, distinguished, or overruled the approach taken here.
Still-open questions
Several legal questions remain open or are not fully resolved by this Local Court decision:
Appellate authority: Whether an appellate court (District Court, Supreme Court, or Court of Criminal Appeal) will accept the magistrate's purposive construction that excludes viability as a legal limit. The magistrate's reasoning is persuasive but not binding on higher courts.
Interaction with lawful abortion jurisprudence: The magistrate referenced authorities (CES v Superclinics; R v Wald; R v Sood) about when abortion may be lawful, but detailed boundaries of lawful medical abortion and statutory exceptions remain matters of higher-court authority and statute. This decision does not displace or fully reconcile those authorities with its holding.
Medical evidence and legislative intent: The decision treats medical definitions as non-decisive when statutory purpose suggests otherwise. There may be contexts where technical medical meanings are more centrally relevant to statutory application, and higher courts could differ about how much weight to give expert medical evidence in construing criminal statutes affecting medical practice.
Sentencing and proportionality: The magistrate reserved sentence. How sentencing courts will calibrate penalty for unlawful self-administration in differing factual circumstances (e.g. late pregnancy, health risk, coercion) remains to be seen.
Legislative remediation: The magistrate noted Parliament had not amended s 82 over more than a century. Legislatures could clarify the statutory terms or create time-based limits; absent such amendment, courts will be asked to fill gaps. Whether Parliament will respond to judicial readings of the statute is an open political question.
Final note: this deep dive reconstructs the Court's reasoning and highlights doctrinal points the magistrate relied upon. It is grounded in the judgment text of Director of Public Prosecutions (NSW) v Lasuladu [2017] NSWLC 11 as provided.
This is general legal information, not legal advice. I can make mistakes. Before you act on, rely on, cite, or use any part of this analysis or any draft, get a qualified Australian lawyer to check it.
Judgment (6 paragraphs)
[1]
Reasons for Decision
The accused Linda Khamis Lasuladu is charged with an offence of self-administer drug with intent to procure own miscarriage an offence under s 82 of the Crimes Act 1900.
Specifically the allegation is that the accused on 3 September 2015, at Toongabbie, in the State of New South Wales, being a woman with child, unlawfully administered to herself a drug, namely, misoprostol, with intent to procure her miscarriage.
The offence is one which carries a maximum penalty of 10 years imprisonment.
The matter proceeded by way of summary hearing before this Court on 25 May 2017 on which date, by agreement between the Crown and the accused's legal representative, the Crown brief of evidence was tendered and marked exhibit one in the proceedings. No prosecution witnesses were required for cross examination.
Both the Crown and defence conceded that the evidence was sufficient to establish a prima facie case in respect to the charge and after having considered the brief of evidence I formed the view that a prima facie case did indeed exist.
The only evidence given in the defence case was evidence from Dr Carol Portman, Obstetrician/Gynaecologist by way of a medical Expert statement and supplementary evidence in chief and cross examination.
I allowed Dr Portman to give evidence over objection from the Crown given the importance of the issues to be decided by the Court and on the very narrow basis that it may provide some context in relation to the current medical meanings of "abortion" and "miscarriage", which might ultimately assist the Court in deciding the legal definition of such words, given that Division 12 of Part 3 of the Crimes Act 1900 to which s 82 relates does not define those words.
In order to properly understand the final submissions made by the parties it is necessary to provide some background relative to the accused and her personal circumstances at the time of the alleged offence. It is also necessary to provide some legislative history in regard to s 82 and Division 12 of Part 3 of the Crimes Act 1900.
[2]
Background of the Accused
The accused at the time of the alleged offence in September 2015 was 28 years old and the mother of five children ranging in age from 4 years to 9 years old. In February 2015 the accused fell pregnant. She commenced attending pre-natal scans and check-ups and continued to so throughout the pregnancy. During this time the accused was in a relationship with her boyfriend Akech Lual, which had commenced in 2012. They formed a plan to marry in 2017.
At about 19 weeks into the pregnancy the accused was informed by her boyfriend Lual that he did not want her to have the child as they weren't married. The accused did not act upon this and continued to attend medical check-ups.
At about 26 weeks into the pregnancy her boyfriend again urged her to terminate the pregnancy. She told her boyfriend that it may be too late to have an abortion. She contacted a number of clinics in NSW and interstate and was refused from all of them on the basis that her pregnancy was past 20 weeks.
The accused eventually found someone she believed was in Darwin, known as "Patrick", who was prepared to facilitate a termination. She contacted Patrick through both the internet and by phone. The person Patrick told her a termination was possible up to 30 weeks and he would send her pills for the payment of $2,000.
Thereafter on 2 September 2015 she received a package originating from South Africa which contained a blister pack of ten pills each containing 200mg of misoprostol, a hormone type substance.
On the 3 September 2015 Patrick provided instructions for inducing an abortion with the misoprostol pills. Thereafter on that day she took six tablets (2 ingested orally and 4 vaginally). She began to feel unwell and was taken by a friend to Blacktown Hospital. At the hospital she presented the blister pack of misoprostol. Subsequent medical intervention disclosed that the foetus was suffering distress. An emergency caesarean section was performed and the child was born.
[3]
Background to the Provisions of Division 12 of the Crimes Act 1900
Division 12 of Part 3 of the Act provides for offences titled "Attempts to Procure Abortion" (ss 82-84).
In particular s 82 provides as follows:
Whosoever, being a woman with child,
unlawfully administers to herself any drug or noxious thing, or
unlawfully uses any instrument or other means,
with intent in any such case to procure her miscarriage, shall be liable to imprisonment for ten years.
Section 83 provides:
Whosoever:
unlawfully administers to, or causes to be taken by, any woman, whether with child or not, any drug or noxious thing, or
unlawfully uses any instrument or other means,
with intent in any such case to procure her miscarriage, shall be liable to imprisonment for ten years.
Section 84 provides:
Whosoever unlawfully supplies or procures any drug or noxious thing, or any instrument or thing whatsoever, knowing that the same is intended to be unlawfully used with intent to procure the miscarriage of any woman, whether with child or not, shall be liable to imprisonment for five years.
As can be discerned from the abovementioned sections, they differentiate between unlawful acts committed on the one hand by a woman with child (s 82), unlawful actions by another to the woman with child (s 83) and unlawful acts of supplying or procuring a drug or noxious thing, or any instrument intended to be unlawfully used with intent to procure a miscarriage (s 84).
These sections came into force upon the commencement of the Crimes Act in 1900, and in particular section 82 has not, as I understand the submissions, been subject to any statutory amendment by Parliament since. The sections speak specifically in relation to the "procurement of a miscarriage".
The heading of Division 12 however speaks specifically of "Attempts to Procure Abortion". The heading was inserted into the Crimes Act by the Statute Law (Miscellaneous Provisions) Act No. 53 of 2000, assented to on 29 June 2000.
In order to establish an offence under s 82 the prosecution must prove three essential elements beyond reasonable doubt:
1. The accused was pregnant; and
2. Unlawfully either:
1. administered to herself a drug or noxious thing; or
2. used an instrument or other means; and
1. Intended to procure her miscarriage
[4]
The Parties' Arguments
The Crown argues that in relation to the element in question that the Court need only be satisfied of the accused's 'intention to procure' the said miscarriage and submits that this is clearly made out on the evidence. The Crown highlighted that there is no guiding authority in this jurisdiction relative to the question in issue, however referred the Court to the decision in R v Spicer (1955) 39 Cr App R 189. In that case the Court considered circumstances where an accused attempted to procure a miscarriage in a woman by manual manipulation of the foetus in the woman's womb. A miscarriage did not occur at that time but some ten days later following the procedure. The accused in that matter was convicted.
Finnemore J directed the jury in the following manner:
Whether this act does or does not produce a miscarriage does not matter. The question is what did he intend to do when he did the acts.
The Crown says that in the current proceedings "the outcome or the ability to achieve the desired outcome is not a relevant consideration". What is relevant are the actions and words of the accused that make clear her intention by taking the misoprostol pills.
The Crown contends that there is ample evidence in the brief to satisfy the intention to procure.
The Crown further submits that as the words "miscarriage" and "abortion" are not defined within the Crimes Act 1900 then the words should be taken on their ordinary and current meaning and that dictionaries are useful in that regard, citing the decision in Manly Council v Malouf t/as Fusion Point (2004) 61 NSWLR 394 at [8].
The Crown also referred to the statement of Lord Coleridge in R v Peters (1886) 16 QBD 636 at 641:
I am quite aware that dictionaries are not to be taken as authoritative exponents of the meanings of words used in Acts of Parliament, but it is a well-known rule of courts of law that words should be taken to be used in their ordinary sense and we are therefore sent for instruction to these books.
The same was cited by Beazley ACJ in the decision of Norrie v New South Wales Births Deaths and Marriages [2013] NSWCA 145 at [84].
The Crown also referred to the "purposive approach" to statutory interpretation and the NSW Interpretation Act 1987. The Crown says that prior to the commencement of the Interpretation Act the common law "purposive approach" to legislation was applied. Within this was a consideration of the so-called mischief rule. The mischief rule referred to the decision in Heydon's Case (1584) 3 Co Rep 7a at 7b, where the Court defined an approach for the "sure and true interpretation of statutes in general" and for consideration of the "mischief" for which it was intended to deal with and by adopting an interpretation of the words that was consistent with than purpose.
[5]
Consideration of the Arguments
Before determining the issues advanced by the parties. I pause to note the following. The ongoing debate regarding pro- and anti-abortion is a polarising issue within the community.
It is not the role of this Court or for me to express views either away about contentious community issues or to determine matters based on a personal viewpoint. My function is to interpret the law where necessary and to apply that law to the given facts of a particular case based upon the statute as intended by parliament on behalf of the whole community.
The resolution of this matter rests upon what ultimately is defined at law as either a miscarriage or an abortion to satisfy the third element of the offence. I accept the proposition that this calls for the Court to embark upon an exercise of statutory interpretation in the absence of either a definition within the legislation or binding legal authority.
The starting point of course is to consider the ordinary meaning of the words to be found in in both the Oxford English Dictionary and the Macquarie Dictionary which define the meaning of the word miscarriage as "the spontaneous expulsion of a foetus from the womb before it is able to survive independently" and for the word abortion "the deliberate termination of a pregnancy". It is to be noted that the Macquarie Dictionary whilst using slightly different words is not dissimilar in its meaning of the terms.
To the extent necessary I would conclude that those definitions apply to an offence under section 82 of the Crimes Act, and indeed where also referred to in sections 83 and 84 of the Act.
That said however I am not of the view that the issues raised by the accused as to whether the foetus is pre-viable or viable has relevance in relation to the offence. In considering that one needs to consider the purposive intent or object of the section. In other words, what was or still remains as the intention of Parliament in enacting the section?
In my view the clear intent of the Parliament was to enact provisions which would hold persons criminally responsible for unlawful acts towards a foetus causing either a miscarriage or an abortion to occur. In essence, protection for a foetus from the time of conception through all stages of pregnancy to the point of birth.
[6]
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Decision last updated: 22 March 2018
Magistrate Hiatt found the accused acted with intent to procure her own miscarriage and was satisfied beyond reasonable doubt that the offence under s 82 was made out; conviction established; parties to be heard on sentence.
In the course of the proceedings the accused's legal representative conceded that the Court would be satisfied beyond reasonable doubt as to establishment by the Crown on the facts of the matter that the first and second elements are made out.
Both parties also agree that as at 3 September 2015 (the date of the alleged offence) the accused was carrying a foetus of 28 weeks of age.
The arguments ultimately advanced to the Court for consideration have therefore focused on the third element as to whether the accused intended as a consequence of the second element to procure her miscarriage.
Dr Portman, a Fellow of the Royal Australian College of Obstetrics and Gynaecology, gave evidence for the accused in relation to the medical meanings of "miscarriage" and "abortion".
She indicated that a miscarriage is considered a pregnancy loss under 20 weeks of gestation or the foetus being under 400 grams. Post 20 weeks the death of the foetus is considered to be a still birth. She further indicated that in this day and age a miscarriage is something that is a spontaneous event not a deliberate event but it is primarily in situations that are considered pre-viable and that is now 20 weeks. Viability might have changed over time but it is pre-viability that is considered a miscarriage. She stated that pre-viable means that the foetus cannot survive on its own.
Dr Portman further indicated that on her understanding of the brief of evidence that the foetus was 28 weeks old and thus a viable foetus.
As to the term "abortion" Dr Portman described this as a deliberate or induced event generally at a time when the foetus is expected to die as a result of the event. The term "abortion" has been used in the past to include pregnancy losses that were also spontaneous and so they would usually have a pre-fix such as "spontaneous abortion", which in these days is considered to be a miscarriage that happens by itself under 20 weeks; and then you have a missed abortion, which is called a missed miscarriage, where the foetus passes away under 20 weeks but hasn't actually come out by itself.
In cross examination Dr Portman was asked about her understanding of the drug misoprostol and it having an anti abortifacient effect. She agreed that is the case. When further questioned she agreed that this drug when taken does not discriminate between ages of a foetus and when taken regardless of the stage of the pregnancy brings on labour and can lead to the death of the foetus or baby.
Further reliance was made by the Crown on s 33 of the Interpretation Act which states:
In the interpretation of a provision of an Act or statutory rule, a construction that would promote the purpose or object underlying the Act or statutory rule (whether or not that purpose or object is expressly stated in the Act or statutory rule or, in the case of a statutory rule, in the Act under which the rule was made) shall be preferred to a construction that would not promote that purpose or object.
Further, reliance was also placed on s 35 of the Interpretation Act and the use of the word "abortion" in the heading to the Division.
Ultimately the Crown submits that in using the words "miscarriage" and "abortion" in the statutory provision, it was not the intention of Parliament under Division 12 of Part 3 of the Crimes Act to only regulate unlawful conduct relating to miscarriages as being prior to the non-viable gestation period. The purpose and intent of the section being to protect the safety and health of all unborn children in the womb from unlawful termination of the pregnancy at all stages of a pregnancy from conception to birth, not only at a particular stage.
In support of its argument the Crown tendered excerpts from the Oxford English Dictionary and the Macquarie Dictionary as to the meaning of the terms "miscarriage" and "abortion". The defence took no issue with this.
The Oxford Dictionary defines a "miscarriage" as:
The spontaneous expulsion of a foetus from the womb before it is able to survive independently.
The Macquarie Dictionary defines it as:
The premature expulsion of a foetus from the uterus, especially before it is viable.
The Oxford Dictionary defines "abortion" as:
1. The deliberate termination of a human pregnancy. 2. The natural expulsion of a foetus from the womb before it is able to survive independently.
The Macquarie Dictionary defines the same as:
a. the removal of a foetus from the mother's womb before it is viable.
b. Also spontaneous abortion, the involuntary expulsion of a foetus before it is viable.
The accused argues that by way of medical definition a miscarriage in relation to pregnancy is a circumstances which occurs when the foetus is 20 weeks or under and that the foetus is non-viable, that is to say, not able to survive outside the womb independently.
In support of that contention the accused relies upon the evidence of Dr Portman in these proceedings.
Recourse is also had to s 33 of the Interpretation Act which supports the proposition that an interpretative construction of an Act or statutory rule should be done in such a way which promotes the underlying purpose or object of an Act or statutory rule, as opposed to a construction which would not promote that purpose or object.
In my view the delineation of the term miscarriage by reference to categories of pre-viable and viable, if the defence argument is accepted, would produce the absurd notion that it is illegal to unlawfully procure a miscarriage when a foetus is pre-viable but legal to unlawfully do so when the foetus is viable. It is not my view that this was the intent of the legislature in enacting the provision.
Whilst Dr Portman's evidence is illuminating in respect to current medical definitions by which it can be seen that there a number of sub-categories for the terms miscarriage and abortion, to accept that evidence as definitive in a legal sense as to what the intention of Parliament was and is only adds further uncertainty.
Further, in rejection of that evidence I have had regard to the decision in Pepsi Seven-Up Bottlers Perth Pty Ltd v Commissioner of Taxation (1995) 62 FCR 289 at [32] where Hill J stated:
It is well established at common law that Courts will refuse to admit evidence for the purpose of interpreting a word used in a statute in accordance with its ordinary meaning.
In my view the terms miscarriage and abortion in this case should be read as being terms referable in their ordinary sense to the termination of a pregnancy which may occur either naturally or unnaturally, legally or illegally, governed by its particular factual circumstance.
The overriding import of Division 12 of Part 3 of the Crimes Act which incorporates s 82, 83 and 84 in my view is thus to render it illegal to unlawfully terminate a pregnancy by either means of an abortion or a miscarriage. Noting that as held in CES v Superclinics (Australia) Pty Ltd (1995) 38 NSWLR 47 applying R v Wald (1971) 3 DCR (NSW) 25 and the decision in R v Sood [2006] NSWSC 762 as they relate to the lawfulness of an abortion in certain factual situations.
Of course I also note that there will be many circumstances in which a miscarriage will tragically occur during the course of a pregnancy by natural means. The current matter is of course not such a circumstance. Simply put the actions of the accused were intended to bring about the unlawful termination of her pregnancy.
The clear fact is that had Parliament intended for there to be time periods during which an offence is or is not committed during a pregnancy then the Parliament would have defined that in the Act or at the very least amended the Act to reflect that position. Given that Parliament has not done so throughout the last 117 years of the provision being in force to my mind speaks to the intention that the offence is designed to cover all stages of a pregnancy.
During the course of argument the accused's legal representative raised the issue that "the way the section is drafted causes problems because a miscarriage seems to be the spontaneous thing or event which occurs resulting in the foetus not surviving". I don't ascribe to that view. The section in my view is directed towards an unlawful activity which procures an event of either a miscarriage or an abortion and it makes no difference whether the foetus survives independently or not outside the womb.
In R v Sood [2006] NSWSC 1141 Simpson J dealing with an offence under s 83 of the Crimes Act (offences relating to the unlawful administration of a drug by another person to a woman to procure a miscarriage) said at paragraph [32]:
The offence of unlawful administration was completed when Ms Sood inserted a tablet into LT's vagina.
On the facts of the current matter the offence with which Ms Lasuladu has been charged under the provisions of s 82 was completed at the point where she both ingested the misoprostal tablets and also inserted them in her vagina with the clear intent to procure a miscarriage.
As a consequence of the foregoing I am satisfied beyond reasonable doubt that the accused in respect to the third element of the offence acted with intent to procure her own miscarriage that being to bring about a spontaneous expulsion of the foetus from her womb having taken the drug misoprostal.
I accept having read the Crown brief of evidence in the matter that the amended statement of facts outlined in pages 1 to 3 of the Crown tender bundle are the facts which the Court would find proved beyond reasonable doubt for the purposes of sentence.
I will hear the parties as to sentence.
Magistrate G Hiatt
Blacktown Local Court
5 July 2017