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 the Philippines has yet to be adjudicated by the Philippine Supreme Court. Proposals to liberalize Philippine abortion laws have been opposed by the Catholic Church, and its opposition has considerable influence in the predominantly Catholic country. However, the constitutionality of abortion restrictions has yet to be challenged before the Philippine Supreme Court. The constitutional provision that "[The State] shall equally protect the life of the mother and the life of the unborn from conception" was crafted by the Constitutional Commission which drafted the charter with the intention of providing for constitutional protection of the abortion ban, although the enactment of a more