Comparative Analysis of Abortion Caused by Sexual Assault in the Laws of Iran, Indonesia, and Malaysia

In Iran, Indonesia, and Malaysia, abortion due to rape. has turned into a social issue, and on the other hand, in some of these countries, the difficulties in this field have been doubled due to lack of decision of laws. In Iranian law, abortion due to rape has not been clearly decided by the legislator, and abortion is allowed only subject to certain conditions just in paragraphs “A”, “B”, and “C” of the Article 56 of the Family Protection and Population Youth Law. In general, it should be acknowledged that even if it was possible under Iranian law, abortion due to rape would only be permissible under Article 56 of the Family Protection and Population Youth Law. However, the legislator of Indonesia has explicitly addressed abortion due to rape. in its laws, and if there are conditions, it is possible to have an abortion up to the 40th or 42nd day of pregnancy according to the words of Shafi'i jurist. Moreover, Malaysian law does not explicitly specify the permits for abortion due to rape; however, according to the existing criteria set by the legislator, such a permit may be considered.