Your Excellency Archbishop Paglia,

“Among all the crimes which can be committed against life, procured abortion has characteristics making it particularly serious and deplorable. The Second Vatican Council defines abortion, together with infanticide, as an “unspeakable crime”. Gaudium et Spes, N.51, “Abortus necnon infanticidium nefanda sunt crimina”.


To begin, these revised Ministry of Health Guidelines are not themselves likely to change anyone’s already-existing basic positions with respect to one of the most painfully heartrending of bioethical debates. The Guidelines introduce regulatory modifications to the implementation of the Italian law that permits abortion under certain circumstances, Law Number 194 of May 22, 1978. Thus, that law has to provide the framework for our discussion, and due consideration of its provisions can help to clarify the meaning, and the risks, of the revised Guidelines.


Paragraph 1 of the PAV’s response introduces the Revised Guidelines to the Abortion Law considering it in the light of Articles (1) and (2) of the 1978 Abortion Law. There is no condemnation of the 1978 abortion law or of the increased killing which will result from this amendment on chemical abortion.

Law 194 begins with the binding affirmation that the State, by guaranteeing the right to maturely considered and responsible procreation, “ recognizes the social value of motherhood and exercises protective concern for human life from its beginning.” It is within this  framework that, while allowing voluntary termination of pregnancy under certain conditions, the same first Article of the law also provides that abortion may not be used as a “method of birth control.” Then, Article 2 of the law, speaking of the role of [government] family counselors, entrusts to them a much broader role than that of mechanically providing information leading to a choice that the S tate simply notes and of which it oversees the “safe and effective” implementation. Under the law, it is the duty of family counselors to assist in overcoming the causes that could lead women to choose abortion, and the information they furnish about rights and services is to have that purpose as well.


Here you state in an evenhanded way that the law of 1978 supports the social value of motherhood, the protection of human life from its beginning and abortion. In a somewhat less evenhanded way, in the Italian version you employ  the euphemism​ “l’interruzione della gravidenza” ​ in defiance of the words of  Saint John Paul II, your Founder. ​“Especially in the case of abortion there is a  widespread use of ambiguous terminology, such as “interruption of pregnancy”,  which tends to hide abortion’s true nature and to attenuate its seriousness in  public opinion.” ​ N58  Evangelium Vitae.   It is to be commended that subsequently you urge the implementation of  existing pro-life guidance in government family counseling. However, your  non-judgemental consideration of the provision of pro-abortion counseling (i.e.“the availability of the most effective and safe tools…”) is to be regretted.  Such terminology is​ ​reminiscent of the slogan “​abortion should be safe, legal  and rare​ ”. The fact that there have been 4 million surgical abortions in Italy  since 1978 is overlooked. The fact that yet more human lives will be lost  between seven and nine weeks is omitted.

“​That is why, before evaluating what is new in the Guidelines, it is important to emphasize once again that society has largely ignored those legal requirements, which could have been, but still could be, at least a partial basis for seeking, nourishing, and sharing a ​civilization that affirms life​. ​ To recoup, ​ we need to talk seriously about a commitment to give women (and couples), really, every possible support to prevent abortion by overcoming those difficulties, even economic ones, that can make abortion a “fate” that is not really “chosen”—the result of negative circumstances that render the thought of having a child difficult or even unbearable and that, in some ways, have pushed Italy, with other countries and even more than others, toward that demographic winter whose consequences we are beginning to see.​”

In this section you make several positive points. When can we expect you to  publish your moral evaluation of the new Guidelines?

“​Il declino di una efficace azione dei consultori familiari evidenzia questo disimpegno, che tende in realtà a far gravare in modo sempre più pesante sulle spalle della (sola) donna l’onere di un gesto che lascia profonde tracce nella sua biografia.​”

“​Lack of effective action on the part of family counselors reflects those same circumstances, which in reality tend to burden only women with the profound and life-long consequences of a decision about bringing new life into the world.​”

Here we have juxtaposed the Italian and English version of the Nota. The Italian  version is satisfactory as it expresses the lifelong consequences on a woman of  having an abortion. Whereas the English suggests the opposite. That is, in fact,  that there is a lack of pro-abortion counseling resulting in lifelong regret about  having a baby which is the contrary of what the Italian states. Are we to assume  this is a translation error?

“​This is the context within which to consider the Guideline revisions just issued. The first deals with removing the requirement that the full protocol of chemical abortions be performed on an inpatient basis (but in reality that requirement has been often by-passed). Now, the drugs can be administered or furnished to an outpatient, followed by the expulsion of the dead embryo from the mother’s womb after she has returned home. If the mother’s concomitant physical pain becomes too intense or she experiences complications, particularly excessive bleeding, a dedicated emergency healthcare facility is to be available. The second change extends the time within which a chemical abortion may be performed—up to nine completed weeks of gestational age (63 days) instead of the earlier seven. The surgery can therefore take place at a more advanced stage of pregnancy, when uncertainty and risk may be greater.​”

This paragraph gives a fairly objective count of the protocol.

“​As a first conclusion, the development that these changes represent—leaving aside the obviously fundamental considerations of clinical effectiveness and safety—seems to further transfer to the strictly private sphere an action that has significant emotional, social, and moral relevance. To the opposite, it is crucial that we provide for a broader and more complete conversation about the intense emotive processes that accompany pregnancy, especially in its initial phases. The particular delicacy of pregnancy is a result of the transformation that becoming a mother, becoming parents, brings about. The surprising appearance of another person calls for a consideration of the most personal aspects of life—the body, space, time, plans. In that light, the inconsistency in the revised Guidelines is “clear.” Allowing an abortion, with all the problems it creates, to take place in the home means distancing abortion even further from the web of social relations and from the world of shared responsibility — precisely the web and world that Law 194 attempted to salvage. It might be easy to argue—and with some good reasons—that the hospital environment is not necessarily the best place to provide the intended accompaniment and support or that in any event they come into play ​only during the lead-up ​ to a decision to terminate a pregnancy. But precisely for this reason it is necessary not to give up searching for more suitable methods and tools to bring about a shared project: accompaniment and support for the nascent and conceived life, and for families, remain the test bench for an attentive and caring society that knows how to build its future with wisdom and foresight.​”

The final paragraph stresses the regrettable loneliness of a woman as a result of  these legal changes. However, the detachment with which it refers to “the  fundamental consideration of clinical effectiveness,” which means the aborting  of a baby, is quite unacceptable from a Catholic Academy for Life.    Law 194 claims to promote the social value of motherhood as affirmed by the  exercising of protective concerns for human life through resources such as  government family counselors who are entrusted by the state to help women  overcome the difficulties that might lead her to abortion.   The promotion of such family counseling is a good and just thing. However,  what is unjust is that whilst promoting this aspect of the law there is no  concomitant condemnation of the law itself. Put simply, article 2 was necessary  for the facilitation of the legalisation of abortion in Italy. It is, indeed, at best  naive to accept this camouflaging of the essential wickedness of this law itself.  Notwithstanding your continued use of pro-abortion language, for example
“termination of pregancy,” you truthfully end by saying that the benchmark for  a caring society is the defense of human life.


Your good intention to decrease the abortions figures by the correct application  of the counseling regulations found in Law 194, Article 2, is creditable but  naive. Whereas the reality is that Articles (1) and (2 ) of Law 194 were simply  cosmetic slogans introduced in order to disarm naive Catholic voters into  accepting abortion in 1978. In not opposing the fundamental premise of  abortion it is also deeply naive for you to believe that you can now limit its  applications. ​Your seemingly uncritical acceptance of Abortion Law 194, however implicit it might be, is most unfortunate if not downright bad. Without a forceful denunciation of abortion, your emphasis on the positive elements (e.g., “the project of accompaniment and support”) risks being merely cosmetic in order to sugar-coat the implementation of the evil of abortion. For it should be undoubtedly clear to you, that in so doing you are not fulfilling your duty of upholding the message of the Gospel.

We kindly ask you to answer these questions:

  1. Does the Pontifical Academy for Life accept that direct abortion, that is, abortion willed as an end or as a means, always constitutes a grave moral disorder, since it is the deliberate killing of an innocent human being? Will you publically ​say​ this?
  2. Does the PAV believe no circumstance, no purpose, no law whatsoever can ever make licit an act which is intrinsically illicit, since it is contrary to the Law of God which is written in every human heart, knowable by reason itself, and proclaimed by the Church? Will you publically ​say​ this of Law 194?
  3. Does the PAV not realize that its use of equivocal language is the expression of the very double thinking underlying Law 194?
  4. Does not the essence of your uncritical acceptance of Law 194, however implicit it might be, lie in the fact that you have fallen into that very danger of which you were warned by your Founder St. John Paul II, namely:

“But  today,  in  many  people’s  consciences,  the  perception  of  its  gravity [abortion] has become progressively obscured. The acceptance of abortion in the popular mind, in behaviour and even in law itself, is a telling sign of an extremely dangerous crisis of the moral sense, which is becoming more and more incapable of distinguishing between good and evil, even when the fundamental right to life is at stake. ​ Given such a grave situation, we need now  more than ever to have the courage to look the truth in the eye and  to  call  things  by  their  proper  name,  without  yielding  to  convenient compromises or to the temptation of self-deception.*​ ” Saint John Paul Evangelium Vitae N.58  *emphasis added

8 September 2020
Feast of the Nativity of the Blessed Virgin Mary  Dr. Thomas Ward
President of the John Paul II Academy for Human Life and the Family