[Downloaded free from http://www.jfsmonline.com on Thursday, May 4, 2017, IP: 207.90.10.

21]

Review Article

Infanticide: A Concept
Arneet Arora, Jayanthi Yadav1, Sanjay Kumar Yadav2, Hans Raj Singh
Department of Forensic Medicine and Toxicology, All India Institute of Medical Sciences, 1Deparment of Forensic Medicine and Toxicology, Gandhi Medical College,
2
National Law Institute University, Bhopal, Madhya Pradesh, India

Abstract
Infanticide is killing of a child <12 months of age by a mother who has not fully recovered from the effects of pregnancy, giving birth and
lactation, and suffers some degree of mental disturbance. However, in India, infanticide means unlawful destruction of a newly born child
and is regarded as murder in law and is punishable under section 302 completely neglecting postpartum psychiatric state of mothers’ mind.
Several studies have indicated a high incidence of postpartum depression in mother of developing as well as developed countries. The lack
of awareness in medical fraternity, legal experts, and society leads to miscarriage of justice. In this article, we have compared legal status
of infanticide in various countries vis‑a‑vis India and thus tried to arrive at a more humane and pragmatic approach in cases of infanticide
keeping in mind the psychological state of mother, gender inequality, weak public health infrastructure, and the prevalent practice of homicide
of unwanted/female child. A psychiatric or medical assessment model of mother by panel of experts in case of infanticide should be evolved.
Information and awareness of postpartum psychiatric illness among medical professionals, legal persons, and society is an important aspect.

Keywords: Compos mentis, infanticide, postpartum depression, puerperium

Infanticide partum: delivery; natum: childbirth). This period has immense

physical, emotional, social, and endocrinal challenges for the
Infanticide at the outset may seem to indicate killing
mother and is together responsible for her altered psyche.
of an infant akin to the term “homicide” which means
Puerperium is generally accepted to be the period of 6 weeks
killing of one human being by another or “suicide” which
after delivery although some consider it to be of 6 months
is killing of self, but is not and its meaning needs to be
duration. When considered to be 6 months, it is divided into
understood.
three phases ‑ acute phase: as 6–12 h after delivery, subacute
Infant is a term used clinically for a child up to the age of phase: as 2–6 weeks, and delayed phase: up to 6 months after
1 year. Infanticide is killing of a child under 12 months of delivery.
age by a mother who has not fully recovered from the effects
of pregnancy, giving birth and lactation, and suffers some Psychiatric Aspects of Puerperal Period
degree of mental disturbance.[1,2] The reason or the cause for
Postpartum mood disorders have been categorized into three
infanticide is the altered mental state of the mother. Filicide is
types: postpartum blues (baby blues), postpartum depression or
a broader meaning word and implies homicide of a child by a
postnatal depression (PPD/PND), and postpartum psychosis.[3]
parent. The reasons for filicide range from personal to social
or environmental and may be further linked to status in society, Postpartum blues is a mild postpartum mood disorder,
the practices and laws in force related to use of contraceptives transient phenomenon characterized by sad or labile mood,
and abortion, the pregnancy being as a result of rape or the and tearfulness lasting from a few hours to a few days. PPD
baby being unwanted for some reason.

Infanticide and Puerperal Period Address for correspondence: Dr. Hans Raj Singh,
Department of Forensic Medicine and Toxicology, All India Institute of
The mother after giving birth to the child is said to be in the Medical Sciences, Bhopal ‑ 462 020, Madhya Pradesh, India.
postpartum or the postnatal or the puerperal period (postafter; E‑mail: jayanthiyadav@yahoo.co.in

Access this article online This is an open access article distributed under the terms of the Creative Commons
Quick Response Code: Attribution-NonCommercial-ShareAlike 3.0 License, which allows others to remix, tweak,
Website: and build upon the work non-commercially, as long as the author is credited and the new
www.jfsmonline.com creations are licensed under the identical terms.

For reprints contact: reprints@medknow.com

DOI:
10.4103/jfsm.jfsm_51_15 How to cite this article: Arora A, Yadav J, Yadav SK, Singh HR. Infanticide:
A concept. J Forensic Sci Med 2017;3:42-6.

42 © 2017 Journal of Forensic Science and Medicine | Published by Wolters Kluwer - Medknow
[Downloaded free from http://www.jfsmonline.com on Thursday, May 4, 2017, IP: 207.90.10.21]
Arora, et al.: Infanticide: A concept
constitutes the affective disorders with severity in between
the blues and psychosis. Postpartum psychosis is the most
severe disorder incapacitating the mother and usually requiring
hospitalization. PPD affects 10%–15% of all women who give
birth.[4] The American Psychiatric Association (APA) describes
postpartum depressive episode as a period of at least 2 weeks
of depressed mood or loss of interest in almost all activities
and changes in appetite, weight, sleep, psychomotor activity,
energy, ability to think, ability to concentrate and ability to
make decisions, or recurrent thoughts of death or suicidal
ideation, plans or attempts. Dr. Dalton, a British obstetrician,
studied PPD and saw an unusual number of women charged
with infanticide or who, under the influence of postpartum
psychosis, have very nearly killed their children. She noted
three varieties of infanticide: those occurring shortly after birth
while the mother is acutely psychotic; those occurring with the
return of menstruation; and those occurring during “domestic
feuds.” According to Dalton, many of these incidents “do not
appear in the press or in law reports and remain hidden from the
public.” In 1971, Dr. Dalton published the results of a survey
conducted on 500 women from birth to 6 months postpartum.
She concluded that 7% of the women developed PPD severe
enough to require medical treatment although none required
hospitalization. Psychiatrists and psychologists now began
to appreciate that depression experienced by new mothers
extended beyond the postpartum blues.[5] It has been reported
that a woman who becomes depressed after giving birth will
reject her baby and show hostility toward him or her.[6] About
25%–50% of women who experience PPD have these types
of depressive episodes for 6 months or longer.[7]
Postpartum psychosis occurs within 1–4 weeks after childbirth
and is suggested as an overt presentation of bipolar disorder
that coincides with hormonal shifts after delivery.[8] The
symptoms are unusual, delirium‑like, and disorganized
psychotic symptoms, such as tactile olfactory and visual
hallucinations. The mother may be compelled to commit
violent acts, and this biologically driven state presents itself
as a toxic organic psychosis complicated by affective mood
changes.[9‑11]
Epidemiological studies have found high rates of depression in
low‑ and middle‑income countries, particularly among women
facing socioeconomic difficulties. The incidence of PPD
varies in literature from 10% to 15%,[3] 20.7%,[12] and 13%[13]
in meta‑analysis of earlier studies. The majority of work to
date has focused on prevalence rates in Asian countries, with
a total of 33 studies conducted in 12 countries in the continent.
Wide ranges in prevalence have been reported both within
and between countries. Estimates have ranged from more
than one‑third of women in a given region (e.g., India and
Pakistan) to 1 woman in 20 in other regions (e.g., Nepal).[14]
Research from India has found that of the 33 women with
PPD, 18 delivered a male baby, compared with 53 of the 268
women without depression  (relative risk  [RR] = 1.02, 95%
confidence interval [CI] = 0.53–1.95; P = 0.82). However, 10 of
the 33 women with depression had specifically wanted a male
Journal of Forensic Science and Medicine  ¦  Volume 3  ¦  Issue 1  ¦  January-March 2017
child but were disappointed with the gender of the newborn
compared with 32 of the 268 nondepressed women (RR = 2.68,
95% CI = 1.38–5.2; P = 0.004). No significant difference was
evident between the depression and nondepression groups
in the women’s preference for a daughter (not a son) and the
gender of the newborn. Disappointment with the birth of a
female child is associated with the development of PND.[15]
In the Finnish population, PPD was found in 9.5% of women
right after giving birth, in 5.9% 2 months after delivery, and
in 8% 6 months after delivery.[16] A later study by Hiltunen[17]
confirmed that 16.2% immediately after delivery and 13%
4 months after suffered from PPD.[7]
The etiology of PPD is not defined, but many studies suggest
that hormonal fluctuation, biological susceptibility, and
psychosocial stressors are the factors involved.[18‑20] Harris
et al. state that maternity blues are experienced by 30% or
more of mothers in the first 10 days after delivery and severe
blues can lead to an episode of major depression.[21] They
also found a modest association between scores for maternity
blues and changes in progesterone concentrations in the
saliva (an accurate measure of circulating free progesterone).
The maternity blues was associated with high antenatal
progesterone concentrations, low postnatal concentrations, and
a steep fall in concentration after delivery. They also suggest
the possibility that it may be possible to attenuate maternity
blues by treating mothers with progesterone.[21] Maternal
depression has been found to correlate with problematic
lives affected by a multitude of negative factors: a low
socioeconomic status, a low level of maternal education, and a
younger age of the mother.[22,23] Depression may also be related
to lack of social support, life stress, and marital conflicts.[24,25]
Prenatal depression is identified as the strongest predictor of
PPD. If the mother experiences any type of depression during
her pregnancy, no matter what trimester, she will be more
likely to retain this depression after giving birth. In addition, a
woman who experiences postpartum blues within the first few
days after giving birth will most likely also experience PPD.[7]
PPD is not defined as a separate entity in the International
Classification of Disease‑10 or the Diagnostic and Statistical
Manual of Mental Disorder IV (DSM IV) and the DSM IV
uses the postpartum onset specifier only if it starts within
4 weeks after delivery (the World Health Organization 1992;
APA 1994).[16] However, PPD is often used as a separate
diagnosis in clinical settings.[26] Many studies do not refer to
new onset cases only, but look at the prevalence of depression
in an inconsistently defined period from 4  weeks to 1  year
after delivery.[7]
Legal Status of Infanticide and Postnatal
Depression in Other Countries
In 1647, Russia became the first country to adopt a humane
attitude and by 1888, all European states except England
established a legal distinction between infanticide and
murder by fixing more lenient penalties to infanticide.
43
[Downloaded free from http://www.jfsmonline.com on Thursday, May 4, 2017, IP: 207.90.10.21]
Arora, et al.: Infanticide: A concept
In 1922 and 1938, England passed the Infanticide Act in
recognition of the time around childbirth as biologically
vulnerable and made infanticide a less severe crime
proscribing sentences of probation and mandatory
psychiatric treatment for women found guilty. Today,
almost all Western societies have adjusted the penalty for
infanticide by recognizing the unique biological changes
that occur at childbirth.[27]
PPD becomes a legal issue only when a mother takes the life
of her child or children, thus involving her in the criminal
justice system. This situation occurs when untreated PPD
causes unintended consequences not for the mother and the
vulnerable child. These consequences can range from simple
child neglect, to child abuse to infanticide, the murder or killing
of a newly born or young child.[14]
The term “PPD” is generally used to describe a disturbance that
can surface sometime after a woman gives birth. Although this
disturbance has been used as the basis for the insanity defense
within the criminal justice system, determining who actually
meets the test for legal insanity is still a major dilemma for
many mothers who are charged with murder or manslaughter
in the USA.[7]
PPD is not an accepted or established defense for infanticide in
the USA. It requires representing and then arguing and it may
still be difficult to justify that PND meets the insanity defense
test of McNaughton rule. Unless this procedure is executed,
even in the USA, it is not possible to ensure rehabilitation for
the woman instead of punishment.
Many times, these cases are unable to establish an insanity
defense claim in the USA because PPD as a mood disorder
may not fulfill the insanity defense test of McNaughton rule,
which only has a cognitive focus.[28]
The M’Naughton rule was formulated in England after Daniel
M’Naughton was acquitted in 1843 on a charge of murder,
when the judges said, “Jurors ought to be told in all cases
that every man is to be presumed to be sane, and to possess
a sufficient degree of reason to be responsible for his crimes,
until the contrary be proven to their satisfaction; and that to
establish a defense on the ground of insanity, it must be clearly
proved that, at the time of committing the act, the party accused
was laboring under such a defect of reason, from disease of
the mind, as not to know the nature and quality of the act he
was doing, or, if he did know it, that he did not know he was
doing what was wrong.”
It is now recommended that definition of Insanity should not
be limited to the M’Naughton test as it focuses only on one
aspect of human nature: knowledge. Volitional conduct can
also determine a person’s actions. M’Naughton’s test also does
not take into account the degrees of incapacity. Insanity test
that still follows M’Naughton need to be reformed to ensure
that mothers convicted of crimes reflecting their state of mind
at the time of crime was committed are not only punished but
also more importantly rehabilitated.[7]
44 Journal of Forensic Science and Medicine  ¦  Volume 3  ¦  Issue 1  ¦  January-March 2017
Scholars, physicians, and courts have agreed that PPD in the
criminal justice system is an issue that cannot be ignored. Both
women and children need protection from this mental illness
that incarceration alone cannot provide. Although screening
may be recognized as the way to diagnose PPD, it also seems
to be the only way of detecting PPD. As a result, it may not
always be effective since there seems to be no alternative
method to check the accuracy of the diagnosis. In addition,
“most women who are depressed after giving birth receive little
or no treatment for their depression either because they are
too ashamed to admit to their ‘unnatural’ feelings or because
their doctors minimize the importance of their complaints.”[7]
Because mothers living in poverty are uneducated on PPD,
have limited access to clinics to get screened for PPD, and are
unable to afford quality screenings, they are at a disadvantage
compared to higher income women. Consequently, criminal
conduct, specifically infanticide, can occur as a result of
undiagnosed and untreated PPD.[7]
Many fear that broadening the insanity defense to include
PPD will create and may have already created a slippery
slope where mothers can be excused of their criminal activity
simply by claiming insanity. Contrary to what these critics
may believe, adopting a broad insanity test that includes PPD
has two important implications. First, the criminal justice
system is not ignorant to disorders that limit mental capacity
specifically affecting women, and second, the criminal justice
system encourages rehabilitation and not just punishment.[7]
Even though PPD is not the most severe mental illness
among the three postpartum mood disorders, the APAs DSMs
describes postpartum depressive episodes to include “changes
in psychomotor activity, ability to think, ability to concentrate,
and ability to make decisions: or recurrent thoughts of death
or suicidal ideation, plans or attempts. ” All these changes are
severe enough to cause the person undergoing these changes
to commit acts that violate the law. In addition, inadequate
social support from family members after a mother gives birth
can perpetuate and enhance a mother’s depressive disorder ‑ a
factor that is highly overlooked in PPD cases.[7]
A study conducted in Japan stated that it is critical for the
pregnant women to obtain prenatal education on postpartum
mood disorders. Also that early contact with a psychiatrist was
the best way to identify the treatment needed for diagnosed
depression.[7]
Legal Status of Infant Death and Postnatal
Depression in India
The patriarchal society in India and China is one of the main
reasons for infanticide in these countries. There are 100
million fewer women in Asia than would be expected and this
numerical worldwide deficit in women and increased female
child homicide is due to gender specific abortions, female
newborn homicide, and neglect.[29]
[Downloaded free from http://www.jfsmonline.com on Thursday, May 4, 2017, IP: 207.90.10.21]
Arora, et al.: Infanticide: A concept
Case have been reported in the state of South India (Tamil
Nadu) and Rajasthan where selective female child homicide
is committed by the mother due to poverty by social stress
of having a girl child as liability and also fear of family
abandoning the mother for giving birth to female child.
One of the cardinal principles of criminal law is based on the
maxim “Actus nonfacit reum nisi mens sit rea.” It means that
the act itself does not make a man guilty unless his intention
was so. From this maxim follows another proposition, “actus
me invite factus non est mens actus” which means an act done
by me against my will is not my act at all. This means that an
act to be punishable by law must be a willed act and at the same
time must have been done with criminal intent. The intent and
the act must combine to constitute the crime.[30]
A person made “noncompos mentis” by illness is exempted
from criminal liability in cases of such acts which are
committed while under the influence of his mental disorder.[31]
Therefore, a woman who is going through postpartum disorder
may consider that she is not able to understand the nature of
act at the time of committing the offense and such an act would
not be considered to be willed act, and she is entitled to be
exempted from the criminal liability.
The mental condition of the accused at the time of committing
the offense is a relevant fact in the Indian Evidence Act. The
onus of proving the mental condition of the accused at the time
of committing the offense is on the accused but that particular
burden of proof is not so heavy in comparison to that of the
prosecution. If the accused can create a reasonable doubt,
then the benefit of doubt would be given to the accused. If the
accused establishes before the court that due to postpartum
disorder she was not able to understand the nature of act at the
time of committing the offense, then benefit of doubt would
be given to the accused.
On the other hand, we cannot ignore the fact that the accused
may use this particular ground to kill systematically the child
of a particular sex.
In urban area, due to medical technology advancement, female
infanticide took the form of female feticide. In urban area
with the help of medical report, we may establish the medical
condition of the accused at the time of committing the offense.
In rural area still in most part of India, the practice of female
feticide is followed. However, it would be very difficult to
establish this particular mental condition of the accused at the
time of committing the offense in the rural area, where such
cases are reported rarely by the family members.
In the present scenario, a female who has committed infanticide
has to stand trial for homicide and if proven insane under
section 84 Indian Penal Code (which is rarely so) she may
be acquitted. However, recognition of PND as a cause of
infanticide or reason behind it is still not accepted by the law.
In Indian scenario where infanticide has occurred as a result
of PND, the female has to plead diminished responsibility.
Journal of Forensic Science and Medicine  ¦  Volume 3  ¦  Issue 1  ¦  January-March 2017
Considering this, the following factors act as a hindrance to
plead for diminished responsibility.
a. Ignorant and uneducated females
b. Poverty
c. Poor access to lawyer and lack of awareness
d. Usually, the females are young mother and would be
unable to successfully plead diminished responsibility.
Indian law presumes every major person to be sane unless
contrary is proved and the burden of proof is on the defense
to prove that unsoundness of mind existed at the time of
committing the offense.
There is no reference to lack of control, irresistible impulse,
diminished responsibility, infanticide, etc.
If infanticide law is passed:
• Burden of proof on prosecution. In case where infanticide
is claimed for an offense the burden of proof would be on
the prosecution to disprove a claim of infanticide beyond
reasonable doubt
• Punishment will include life imprisonment. However, in
practice, noncustodial sentence is usually the outcome.
This will however open the subject to treatment or
hospitalization.[32]
Conclusion
PPD exists in a significant number of women worldwide. In
India, more stress factors exist for a larger proportion of the
population, and hence, the prevalence is likely to be high.
There is also lack of facility of psychiatric assessment in
antenatal period. In the event of an infanticide, we should have
awareness about it and its magnitude to prevent punishment
for an act which on the contrary requires rehabilitation and
treatment.
Ideally, we should be able to provide antenatal psychiatric
screening to all women, identify those likely to have PND
and offer counseling as to how to handle the postnatal period.
In the extreme situation of occurrence of infanticide, we
would be able to better differentiate a malicious act from
an act of Infanticide, with records of clinical evidence of
antenatal period and postnatal medical assessment by panel
of experts.
Financial support and sponsorship
Nil.
Conflicts of interest
There are no conflicts of interest.
References
1. Bourget D, Grace J, Whitehurst L. A review of maternal and paternal
filicide. J Am Acad Psychiatry Law 2007;35:74‑82.
2. Deadman WJ. Medico-legal: Infanticide. Can Med Assoc J
1964;91:558‑60.
3. O’Hara MW, Zekoski EM, Philipps LH, Wright EJ. Controlled
prospective study of postpartum mood disorders: Comparison
45
[Downloaded free from http://www.jfsmonline.com on Thursday, May 4, 2017, IP: 207.90.10.21]
Arora, et al.: Infanticide: A concept
of childbearing and nonchildbearing women. J Abnorm Psychol
1990;99:3‑15.
4. Wilen JM, Mounts KO. Women with depression‑”You can’t tell by
looking”. Matern Child Health J 2006;10 5 Suppl: S183‑6.
5. Dalton K, Horton WM. Depression After Childbirth. How to Recognize,
Treat, and Prevent Postnatal Depression. 4th ed. New York: Oxford
University Press; 2001.
6. Dalton K. Depression After Childbirth. How to Recognize and Treat
Postnatal Illness. New York: Oxford University Press; 1980.
7. Yang V. Postpartum deprassion and the insanity defence: A poor
mother’s two worst nightmares. Wis J Law Gend Soc 2009;1:229‑53.
8. Sit D, Rothschild AJ, Wisner KL. A review of postpartum psychosis.
J Womens Health (Larchmt) 2006;15:352‑68.
9. Wisner KL, Gracious BL, Piontek CM, Peindl K, Perel JM. Postpartum
disorders: Phenomenology, treatment approaches, and relationship
to infanticide. In: Spinelli MG, editor. Infanticide: Psychosocial and
Legal Perspectives on Mothers Who Kill. Washington, DC: American
Psychiatric Publishing; 2002. p. 36‑60.
10. Sichel DA. Neurohormonal aspects of postpartum depression and
psychosis. In: Spinelli MG, editor. Infanticide: Psychosocial and
Legal Perspectives on Mothers Who Kill. Washington, DC: American
Psychiatric Publishing; 2003. p. 61‑80.
11. Oosthuizen P, Russouw H, Roberts M. Is puerperal psychosis bipolar
mood disorder? a phenomenological comparison. Compr Psychiatry
1995;36:77‑81.
12. Tannous L, Gigante LP, Fuchs SC, Busnello ED. Postnatal depression
in Southern Brazil: Prevalence and its demographic and socioeconomic
determinants. BMC Psychiatry 2008;8:1.
13. O’Hara M, Swain A. Rates and risk of postpartum depression – A
meta‑analysis. Int Rev Psychiatry 1996;8:37‑54.
14. Parsons CE, Young KS, Rochat TJ, Kringelbach ML, Stein A. Postnatal
depression and its effects on child development: A review of evidence
from low‑ and middle‑income countries. Br Med Bull 2012;101:57‑79.
15. Chandran M, Tharyan P, Muliyil J, Abraham S. Post‑partum depression
in a cohort of women from a rural area of Tamil Nadu, India. Incidence
and risk factors. Br J Psychiatry 2002;181:499‑504.
16. Kauppi A. Filicide, Intra Familial Child Homicides in Finland
1970‑1994. Dissertations in Health Sciences No. 118; 2012.
17. Hiltunen P. Maternal postnatal depression: Causes and consequences.
Int J Circumpolar Health 2003;62:308‑9.
18. Harris B. A hormonal component to postnatal depression. Br J Psychiatry
46 Journal of Forensic Science and Medicine  ¦  Volume 3  ¦  Issue 1  ¦  January-March 2017
1993;163:403‑5.
19. Harris B. Biological and hormonal aspects of postpartum depressed
mood. Br J Psychiatry 1994;164:288‑92.
20. Hendrick V, Altshuler LL, Suri R. Hormonal changes in the postpartum
and implications for postpartum depression. Psychosomatics
1998;39:93‑101.
21. Harris B, Lovett L, Newcombe RG, Read GF, Walker R, Riad‑Fahmy D.
Maternity blues and major endocrine changes: Cardiff puerperal mood
and hormone study II. BMJ 1994;308:949‑53.
22. Mandl KD, Tronick EZ, Brennan TA, Alpert HR, Homer CJ. Infant
health care use and maternal depression. Arch Pediatr Adolesc Med
1999;153:808‑13.
23. Templeton L, Velleman R, Persaud A, Milner P. The experiences
of postnatal depression in women from black and minority ethnic
communities in Wiltshire, UK. Ethn Health 2003;8:207‑21.
24. Hagen EG. The functions of postpartum depression. Evol Hum Behav
1999;20:325‑59.
25. Rougé‑Maillart C, Jousset N, Gaudin A, Bouju B, Penneau M. Women
who kill their children. Am J Forensic Med Pathol 2005;26:320‑6.
26. Eberhard‑Gran M, Tambs K, Opjordsmoen S, Skrondal A, Eskild A.
A comparison of anxiety and depressive symptomatology in postpartum
and non‑postpartum mothers. Soc Psychiatry Psychiatr Epidemiol
2003;38:551‑6.
27. Infanticide: Contrasting Views. Archives of Women’s Mental Health;
c2004. Available from: http://www.business.highbeam.com/437752/
article‑1G1‑152515290/infanticide‑contrasting‑views. [Last updated on
2005 May 01; Last cited on  2015 Feb 28].
28. Marion C. The Insanity Defense: An Overview and Legislative Proposals
Library of Congress. Congressional Research Service. American Law
Division 1982 – Defense (Criminal procedure); 1982. p. 22.
29. Female Infanticide. Available from: http://www.en.wikipedia.org/
wiki/female_infanticide.  [Last updated on 2015  Jan  11; Last cited on
2015 Feb 28].
30. Turner JW, editor. Principles of criminal liability. In: Kenny’s Outlines
of Criminal Law. 18th ed.  UK: Cambridge University Press; 1962. p. 14.
31. Turner JW, editor. In: Russell on Crime. 12th ed. UK: Sweet and Maxwell
Ltd.; 1964.
32. Infanticide and the Criminal Law. Available from: http://www.inbrief.
co.uk/court‑proceedings/infanticide‑and‑criminal‑law.htm. [Last cited
on 2015 Feb 28].