In 1968, Morgentaler gave up his family practice and began performing abortions in his private clinic. He devoted his clinic to performing abortions on women as well as providing birth control and contraceptives, though it was illegal at the time. At the time, abortion was illegal except for cases in which continuing a pregnancy threatened the life of the pregnant woman. On August 26, 1969, an amendment to the Criminal Code legalized abortion in Canada if performed in a hospital after approval of a Therapeutic Abortion Committee. There was, however, no requirement for a hospital to set up a committee and only about one-third of hospitals did, leaving many areas without legal abortion, forcing women to travel and inducing barriers and delays. Some committees never met. Even if they did, they never saw their "patient" and yet her fate was determined by their subjective opinions. In addition, there was no appeal of a TAC's decision. In effect, the system was grossly unfair. Morgentaler's abortions remained illegal under that new law because he did not submit them in advance to a TAC for approval; they became legal in 1988, when section 251 of the Criminal Code (now known as section 287) was found to be unconstitutional by the Supreme Court of Canada.