International records / OpenAlex research

Commissioner of Police v. Modebe, 1980.

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 her…