It is humbly submitted to the Court that the Section 3(4)(a) of the Medical Termination of

Pregnancy Act of 1971 seeks to give the legal guardian of the woman who is pregnant to
consent for abortion on her behalf in case she is a minor or mentally-ill, is in accordance with
the International Conventions that are ratified by India, as mentally ill women will not be able
to make decisions on reproductive choices due to their mental state.

The counsel humbly submits that the impugned section is in accordance with the
International Covenant of Economic, Social and Cultural Rights as the Section does not
engage in an activity that has destructed the rights provided in the covenant as the legal
guardian behalf of Ms. Neeta is not mentally stable enough to make her reproductive
decisions that can affect her life. The decision undertaken by the respondent has not led to
any derogation of fundamental human rights.

The counsel also humbly submits that the impugned section is not violative of Convention on
Elimination of All Forms of Discrimination Against Women (CEDAW), the Convention on
Rights of the Persons with Disability (CRPD) and the Declaration of Sexual Rights as when
the woman carrying the child is having intellectual and developmental problems, the decision
to carry the pregnancy cannot be taken by the woman in a rational manner for which the law
provides for the consent of the legal guardian on behalf of her. Section 3(4)(a) of the Medical
Termination of Pregnancy Act of 1971 as a legislative measure is not violative of the rights
given under the International Conventions.