In November 2015, Lord Justice Horner made a declaration of incompatibility under the Human Rights Act 1998 to the effect that Northern Ireland's law on abortion (specifically its lack of provision in cases of fatal foetal abnormality or where the pregnancy is the result of rape or incest) could not be interpreted in a manner consistent with Article 8 of the European Convention on Human Rights i.e. a right to respect for his private and family life, his home and his correspondence; the Convention also protects a right to life in Article 2.