Abortion which midwives usually worked were relatively safe. In addition, some commentators have written that, despite improved medical procedures, the period from the 1930s until legalization also saw more zealous enforcement of anti-abortion laws, and concomitantly an increasing control of abortion providers by organized crime. Soviet Russia (1919), Iceland (1935) and Sweden (1938) were among the first countries to legalize certain or all forms of abortion. In 1935 Nazi Germany, a law was passed permitting abortions for those deemed "hereditarily ill", while women considered of German stock were specifically prohibited from having abortions. Beginning in the second half of the twentieth
Abortion in Queensland of the Supreme Court of Victoria ruled that an abortion performed in the reasonable belief it was necessary to protect the woman's physical or mental wellbeing was lawful, which became known as the "Menhennitt ruling". The Menhennitt ruling was applied in the 1986 Queensland case "R v Bayliss; R v Cullen" by Judge McGuire of the District Court of Queensland, which he considered to mirror the lawful abortion exemption established by section 282 of the Criminal Code. This resulting "McGuire ruling" allowed abortion to protect a woman's physical or mental health, and was upheld on appeal by the Supreme Court