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Abstract

The focus of this submission about Professional Obligations and Human Rights (POHR) is its demand for "effective referral" - the demand that physicians do what they believe to be wrong - even gravely wrong - even arranging homicide or suicide - and the implied threat that they will be punished if they refuse.

This is a dangerous and extraordinarily authoritarian policy, completely at odds with liberal democratic aspirations and our national traditions. The burden of proof is on the working group to prove beyond doubt that it is justified and that no reasonable alternatives are available. The working group has not done so.

The working group provided no evidence that such a policy is necessary, and there is evidence that it is not. The briefing materials supplied to Council in support of POHR were not only seriously deficient, but erroneous and seriously misleading. "Public sentiment" captured by a random poll does not justify the suppression of fundamental freedoms, and the results of consultation, when carefully considered, suggest that a policy of "effective referral" is highly controversial.

An example of a reasonable alternative is available from the Australian Medical Association - an example not offered to Council members by the working group, which, instead, completely misrepresented AMA policy.

This submission, supported by detailed analysis in the appendices, provides good reason for Council members to doubt that the requirement for effective referral in POHR is necessary or justifiable, or prudent policy. It also provides reason for them to believe that reasonable alternatives can be developed.

Council members unpersuaded by the working group or left in doubt about POHR should give the benefit of doubt to freedom of conscience and refuse to approve the draft policy in its present form. They should direct the working group to collaborate with those opposed to the present draft to produce a broadly acceptable text. If the real goal is to ensure access - not ideologically driven ethical cleansing - there is no reason to demand that physicians do what they believe to be wrong. If the College's real goal is to ensure access to services - not to punish objecting physicians, or drive them out of family practice, or out of the profession - that goal is best served by connecting patients with physicians willing to help them.

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Table of Contents

Abstract

I.    Introduction

• Focus of the submission
• What the working group seeks
• Burden of proof
• Responsibility of Council members
• Project submission

II.    Reasons for doubt

• No evidence of necessity
• Questionable justification
  • Public Polling
  • On-line Survey
  • Research
• Deficient, erroneous and misleading briefing materials
• Examples of more reasonable policies
• Policies forthcoming in 2015
• Neglect of relevant significant Canadian documents

III.    POHR in practice

IV.    Giving freedom of conscience the benefit of the doubt

V.    Conclusion

Appendix "A":  The Review Process

Appendix "B":  Unreliability of Jurisdictional Review by College Working Group

Appendix "C":  Consultation on Physicians and the Human Rights Code

Appendix "D": A Case for Evidence-based Policy Making

Appendix "E": Legal Criticism

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I.    Introduction

Focus of the submission

I.1     The Project’s concern with Professional Obligations and Human Rights (POHR) is its demand that physicians must do what they believe to be wrong: that physicians who object to a procedure for reasons of conscience are obliged to provide "an effective referral" even if they find that equally objectionable. That is the focus of this submission.

What the working group seeks

I.2    The working group asks each member of Council

• to approve a policy intended to force physicians who are unwilling to kill patients or help them commit suicide to find a colleague who will;

• to approve a policy intended to force physicians who are unwilling to kill developing infants in utero to find a colleague who will;

• to approve a policy that the chair of the working group has admitted will expose physicians unwilling to participate in killing developing infants in utero to discipline by the College1 and effectively force them out of family medicine;2

• to approve a policy that, since the decision of Carter v. Canada, will expose physicians unwilling to participate in killing patients or helping them to kill themselves to discipline by the College,1 and effectively force them out of family medicine and palliative care.3

I.3    A Council member who approves Professional Obligations and Human Rights will thereby approve the principle that a learned or privileged class, a profession or state institution can legitimately compel people to do what they believe to be wrong - even gravely wrong - even murder - and punish them if they refuse.

Burden of proof

I.4    This is a dangerous and extraordinarily authoritarian policy that is completely at odds with liberal democratic aspirations and our national traditions.  The burden of proof is on the working group to prove beyond doubt that it is justified and that no reasonable alternatives are available.  It is the responsibility of Council members to insist that the working group fully discharges the burden of proof.

Responsibility of Council members

I.5    If a member of Council is to approve such a policy, he or she must have absolutely no doubt that POHR must be adopted, and that no better alternative can be developed.

I.6    On the other hand, if there is any doubt that Professional Obligations and Human Rights is necessary and completely justifiable, or if there is any reasonable possibility that a less authoritarian policy might be drafted, POHR should be rejected.

Project submission

I.7    It is the submission of the Protection of Conscience Project that Council members have  good reason to doubt that the requirement for effective referral in Professional Obligations and Human Rights is a necessary or satisfactory policy.  Further:  Council members have good reason to believe that a less authoritarian policy can be developed. 

I.8    Doubts about POHR should be resolved in favour of freedom of conscience.  Professional Obligations and Human Rights should be rejected.  The working group that produced it should be required to collaborate with those opposed to the present draft to produce a broadly acceptable text. This is consistent with the approach to conflict resolution recommended by the Royal College of Physicians and Surgeons of Canada.4

I.9    The Protection of Conscience Project’s 2014 submission concerning Physicians and the Human Rights Code remains relevant to Professional Obligations and Human Rights (POHR). Among the points made in the previous submission, the following bear repetition here:

. . .it is incoherent to include a duty to do what one believes to be wrong in a code of ethics, the very purpose of which is to encourage physicians to act ethically and avoid wrongdoing. . .

There is a significant difference between preventing people from seeking perfection by doing the good that they wish to do and destroying their integrity by forcing them to do the evil that they abhor.

As a general rule, it is fundamentally unjust and offensive to force people to support, facilitate or participate in what they perceive to be wrongful acts; the more serious the wrongdoing, the graver the injustice and offence. It is a policy fundamentally opposed to civic friendship, which grounds and sustains political community and provides the strongest motive for justice. It is inconsistent with the best traditions and aspirations of liberal democracy. And it is dangerous, since it instills attitudes more suited to totalitarian regimes than to the demands of responsible freedom

II.    Reasons for doubt

II.1    There is reason to doubt that the requirement for effective referral in POHR is necessary or justifiable because

•  the working group provided no evidence that the policy is necessary,

• there is evidence that the policy is not necessary,

• the justification offered for the policy by the working group is doubtful, and

• the briefing materials supplied to Council in December in support of POHR were not only seriously deficient, but erroneous and misleading.

II.2    There is reason to believe that a less authoritarian policy can be developed because

• examples of more reasonable policies can be found elsewhere, or may be forthcoming in 2015, and

• the working group failed to reference significant and relevant documents from Canadian authorities.

No evidence of necessity

II.3    The chair of the working group justifies POHR on the grounds that it is necessary to "facilitate access" to services.3 The working group provided no evidence to support this assertion.

II.4    On the other hand, there is evidence that the effective referral provision in POHR is not necessary to facilitate access to services. The evidence is found in the case of three Ottawa physicians who provide Natural Family Planning assistance in birth control and who refuse to provide, recommend or refer patients for abortion or contraception (Appendix "D").

II.5    Finally, while there is anecdotal evidence of a disturbing pattern of disrespectful communication by physicians,  there are already policies that can deal with this problem, though they may need to be reinforced and enforced. However, the POHR requirement for "effective referral" in order to "facilitate access" to widely available services like contraception and abortion is not necessary.  It is a solution in search of a problem, or, to put it in terms of Charter of Rights jurisprudence, a policy that is unconstitutional because it is "overbroad." (Appendix "D", DIV.)

Questionable justification

II.6    Public Polling: As part of the review process (Appendix "A"), the College surveyed 800 Ontario residents in May, 2014 "to capture public sentiment on conscientious objection in the health services context."

II.7    When POHR was released in December, 2014, Dr. Marc Gabel, then President of the College, stated that this polling demonstrated that "the vast majority of Ontarians believe that [objecting physicians] should be required to identify another physician who will provide the treatment, and make and/or coordinate a referral."5

II.8    There is little doubt that a poll conducted in Alabama in 1950 about racial segregation would have indicated overwhelming popular support for the practice. It is at least doubtful that "public sentiment" is a trustworthy guide for policy makers, particularly with respect to the exercise of fundamental freedoms by minorities.

II.9    On-line Survey: The working group advised members of College Council that "the vast majority of respondents expressed their support for freedom of conscience, and the idea that physicians should not have to provide services that conflict with their moral and/or religious beliefs," but added that the feedback was polarized.6 On the question of referral, the Council was told  "many respondents were in support of a referral requirement" but that "the opposing viewpoint was also strongly represented."7

II.10    Appendix "C" demonstrates that this summary of the consultation process provided by the working group was inadequate and misleading.

II.11    According to the briefing note for College Council, there were 6,710 responses, including "2296 comments posted to the online discussion page and 4414 completed online surveys."8

II.12    In fact, there were 3,103 complete and 1,311 partially completed surveys, not 4,414 completed surveys.9 Moreover, since an unknown number of respondents contributed both to the On-line Survey and Discussion Forum, the number of unduplicated consultation responses actually available for analysis may have been far less than 6,700.  On the extremely contentious issue of referral, for example,  the College's analysis relies on less than half that number (Appendix "C", Figure 13).

II.13    The overwhelming majority of respondents who made submissions through email or regular mail or as discussion forum participants support freedom of conscience for physicians with respect to refusing to provide non-emergency services.  In contrast, they offer virtually no support for a policy of mandatory referral by objecting physicians (Appendix "C", CIV.2).

II.14    Levels of support for policy statements related to freedom of conscience for physicians decrease when they are perceived as excessively rigid or insufficiently attuned to the realities of practice.  Levels of support fall and disagreement and doubt increase when they are perceived to require complicity in morally contested procedures.  On-line Survey responses under this head do not support a policy of mandatory referral, suggesting, instead, that such a policy is highly controversial because it is associated with coerced complicity in perceived wrongdoing (Appendix "C", CIV.3).

II.15    This is illustrated by responses to a "Yes-No-Don't Know" question about agreement with a policy of mandatory referral. Here the level of agreement drops to 50% and the level of disagreement rises dramatically to 43% (Appendix "C", Figure 13). Moreover, the sample of comments provided in the Report indicate that the expressed levels of agreement and disagreement are somewhat unstable, depending on factors or nuances not captured by the survey question.

II.16    Research: The working group told Council members that POHR reflects the results of their research,10 but failed to make public the details of its review of professional literature or case law.11

II.17    In the absence of such information, the public and members of the profession must rely entirely on the working group's assurance that POHR faithfully reflects what is found in legal and professional literature.  Council members were similarly dependent upon the information provided by the working group during the December meeting.

II.18    The claim that the kind of policy proposed in POHR is consistent with human rights legislation and jurisprudence was challenged by lawyers who made submissions during the preliminary consultation (Appendix "E"). It is the Project’s understanding that further legal submissions specific to POHR will be made to the same effect, so this issue is not pursued here.

II.19    A second reason to question the reliability of the working group's research into professional literature and law is that, with respect to much simpler research concerning policies in different jurisdictions, the briefing material provided to Council members in December was deficient, erroneous and misleading.

Deficient, erroneous and misleading briefing materials

II.20    With respect to the issue of physician freedom of conscience and referral in particular,

A. the accounts provided of the policies of the Canadian Medical Association were deficient;

B. the accounts provided of the policies of the Colleges of Physicians of British Columbia, Alberta, Nova Scotia, Prince Edward Island, Newfoundland, New Brunswick and Quebec were deficient;

C. the information provided concerning the Australian Medical Association was erroneous and seriously misleading;

D. the information provided concerning New Zealand was deficient and seriously misleading;

E. the account provided concerning policies in the United States was deficient and superficial;

F. the account provided concerning nursing policies in Ontario was deficient and misleading;

G. the account provided in Appendix 3 concerning midwifery policies in Ontario was deficient;

H. briefing materials failed to reference significant documents from Canadian authorities relevant to the issues.

II.21    Particulars of the deficiencies are provided in Appendix "B". In some cases, the deficiencies are fully accounted for by the fact that the working group did not know about the existence of correspondence between the Protection of Conscience Project and Colleges of Physicians concerning the meaning of their policies.

II.22    However, in many cases, the errors and deficiencies are not easily explained: for example, the grossly inaccurate presentation of the position of the Australian Medical Association concerning the exercise of physician freedom of conscience in general, and referral in particular.

II.23    Especially troubling is the fact that every one of the errors, omissions, and deficiencies (apart from those noted in II.21) tend to favour the demand for "effective referral" in POHR. This gives rise to legitimate concern about researcher bias, which brings into question the soundness of the research undertaken. This is of particular concern to the public and members of the profession, who do not have access to the information presented to Council members during the meeting in December.

II.24    The deficiencies and errors in the briefing materials supplied to Council members by the working group are a direct challenge to Dr. Gabel's assertion that POHR "is nothing new" because similar policies already exist in Alberta, Manitoba, Quebec and New Brunswick.12  

II.25    Notwithstanding the impression that might be created by Dr. Gabel’s claim, the Collège des Médecins du Québec  is the only medical regulator in Canada that requires what POHR calls "an effective referral" by objecting physicians (Appendix "B", BII.2). Moreover, it appears that Quebec's legalization of euthanasia prompted an intuitive recognition that the requirement nullifies freedom of conscience (Appendix "B", BII.2.29).

Examples of more reasonable policies

II.26    Contrary to the briefing material provided to Council members in December, the Australian Medical Association (AMA) supports both patient access to services and physician freedom of conscience, including the freedom to decline to provide "an effective referral" (Appendix "B", BII.3).

II.27    In 2013 the AMA produced a lengthy and thoughtful statement about physician exercise of freedom of conscience called Conscientious Objection (BII.3.9).  Although this document is readily available on the AMA website, the working group did not provide Council members with extracts from it, or, indeed, even refer to it in the jurisdictional review.  The AMA's Conscientious Objection differs markedly from POHR in tone and, unlike POHR, leaves the impression that it was produced through the kind of collaborative process recommended for conflict resolution by the Royal Society of Physicians and Surgeons of Canada.13

Policies forthcoming in 2015

II.28    The working group selected the American Medical Association as one of the international authorities suitable for policy comparison.  However, rather than citing Association policy documents, it provided Council members with only a single sentence taken from a journal article about conscientious objection among pharmacists (BII.5.1).

II.29    In November, 2014, the American Medical Association House of Delegates adopted a new policy concerning physician exercise of freedom of conscience, which will be formally issued in June, 2015 (BII.5.2). The College Council meeting at which POHRC will be discussed is scheduled for the end of May.  It is open to Council members who are doubtful about POHR to postpone consideration of the draft until the fall.  By that time they will have had the opportunity to consider the new policy issued by the American Medical Association, which is likely to be more informative than the single sentence they were given by the working group.

II.30    Postponing consideration of POHR until the fall is unlikely to be problematic, since the working group has produced no evidence that anyone in Ontario has been denied access to services or procedures because physicians have exercised freedom of conscience (II.3).

Neglect of relevant significant Canadian documents

II.31    The Canadian Medical Association, Canadian Healthcare Association, Canadian Nurses' Association and Catholic Health Association of Canada have produced a Joint Statement on Preventing and Resolving Ethical Conflicts involving Health Care Providers and Persons Receiving Care that has been cited by the Supreme Court of Canada and the Royal College of Physicians and Surgeons of Canada (Appendix "B", BII.8). 

II.32    The working group did not refer to this document, and  POHR is inconsistent with its approach.

II.33    The Royal College of Physicians and Surgeons of Canada discusses conflict resolution at length, and stresses that a collaborative approach is the preferred method that leads to "creative, durable outcomes."14 It is not evident that the working group has hitherto been inclined to adopt a collaborative approach in developing POHR.

III.    POHR in practice

III.1    Council members may also conclude that for practical reasons connected with the realities of medical practice, the effective referral requirement in POHR is ill-advised. A practical example is available from Australia.

III.2    Despite the opposition of the Australian Medical Association and others, in 2008 the government of the Australian state of Victoria passed an abortion law that includes a requirement for the kind of effective referral contemplated in POHR (Appendix "B", BII.3)

III.3    In April, 2013, a physician in the state of Victoria who is opposed to abortion for reasons of conscience15 publicly announced that he had refused to provide a referral for a woman who had come to him seeking an abortion. His statement presented a challenge to the state government and medical regulator to prosecute or discipline him for his refusal.16

III.4    Responding to the media, a spokeswoman for the Medical Practitioners Board warned that all doctors were bound by the law and by their code of conduct, and that they were expected "to practise lawfully" and meet professional standards.16

III.5    The physician was adamant and unrepentant in his refusal, and the case repeatedly made the news, even outside Australia. For at least five months he was the subject of an investigation by the state Medical Board. The investigation was based on a newspaper article and initiated by a member of the Board because the woman refused the abortion did not complain.17

III.6    Ultimately, the physician was cautioned for allegedly having made a statement in the media that he would not obey the law, but he was not cautioned for refusing to refer for abortion, as required by the law.18 It appears that, the law notwithstanding, no one in a position of authority was prepared to prosecute, discipline or even caution a physician who refused to refer a woman 19 weeks pregnant for a sex-selective abortion; she and her husband did not want a girl. They obtained an abortion elsewhere a few days later without the assistance of the objecting physician.17

III.7 This case was cited by the Victorian branch of the Australian Medical Association to illustrate one of the reasons the Association was opposed to the mandatory referral provision in the law. A spokeswoman said:

"We disagreed with the conscientious objection clause for a number of reasons, including people’s rights not to be involved in activities which offend their conscience, but also because of the impracticality of the clauses which have been included."

She said Dr Hobart's case highlighted these impracticalities, "ie that it is hard for a doctor to judge whether or not another doctor would or wouldn’t hold an objection in a particular circumstance."19

III.8    This statement by AMA Victoria was made five months after the association published the fact sheet provided by the working group that implied the AMA’s support for a policy of mandatory referral (Appendix "B", BII.3).

III.9    Two further points should be noted. First: sex-selective abortion is legal in Canada, as it is in the state of Victoria, so a case of this kind can arise here. Second: the woman was obviously able to access sex-selective abortion without the assistance of the objecting physician, as a woman would be able to access sex-selective abortion here. This further demonstrates the point made in II.5: that the POHR requirement for "effective referral" in order to "facilitate access" to widely available services like contraception and abortion is a solution in search of a problem.

IV.    Giving freedom of conscience the benefit of the doubt

IV.1    The preceding arguments, supported by detailed analysis in the appendices, provide good reason for a Council member to doubt that the working group has demonstrated that the requirement for effective referral in POHR is necessary, justifiable or prudent policy.

IV.2    The working group provided no evidence that the policy is necessary. In contrast, there is evidence that it is not necessary.

IV.3    Neither the poll conducted by the working group nor its consultation can be cited to support a policy of "effective referral." Public sentiment captured by a random poll of people who may have no understanding of the issues is an unreliable guide to the formulation of policy about the exercise of fundamental freedoms. The results of the consultation not only fail to support a policy of mandatory referral, but suggest that such a policy is highly controversial because it is associated with coerced complicity in perceived wrongdoing. In light of this, a Council member is justified in taking a sceptical view of POHR.

IV.4    A Council member is also entitled to entertain grave doubts about the acceptability of POHR because of the seriously deficient, erroneous and misleading material provided by the working group in its jurisdictional review.

IV.5    The statement of the Australian Medical Association gives a Council member good reason to believe that a more reasonable policy can be developed if the working group attends to advice from neglected Canadian authorities and adopts the collaborative approach recommended by the Royal College of Physicians and Surgeons of Canada.

IV.6    Finally, the case of the physician in the state of Victoria, Australia, illustrates the kind of conflicts that can be generated by a policy of "effective referral"  -  unnecssary conflicts generated by a policy that, moreover, is not necessary to ensure "access" to services. 

IV.7    It is not necessary for a Council member to disprove the claims made by the working group in support of Professional Obligations and Human Rights. Rather, the burden is on the working group to prove to Council members that the suppression of fundamental freedoms entailed by POHR is justified, and that no practical problems will arise if POHR is adopted.

IV.8    A Council member unpersuaded by the working group or left in doubt about POHR should give the benefit of doubt to freedom of conscience and refuse to approve the draft policy in its present form.

V.    Conclusion

V.1    The College of Physicians and Surgeons periodically receives complaints about physicians who have refused to provide a service for reasons of conscience or religion, and has an obligation to respond to such complaints. It is reasonable to ask what kind of response is best suited to the problem.

V.2    Council should direct the working group to collaborate with those opposed to the present draft to produce a broadly acceptable text. If the real goal is to ensure access - not ideologically driven ethical cleansing - there is no reason to demand that physicians do what they believe to be wrong. If the College’s real goal is to ensure access to services - not to punish objecting physicians, or drive them out of family practice, or out of the profession - that goal is best served by connecting patients with physicians willing to help them. That would be a more helpful and practical response than attempting to restrict or suppress freedom of conscience and religion in the medical profession.

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Notes

1.  The following report was based upon interviews with Dr. Gabel and Dr. Carol Leet, President of the College. Neither has ever denied the accuracy of the report.

Dr. Marc Gabel, a Toronto psychotherapist and past president of the college, told LifeSiteNews on Thursday that if his committee's proposed revision of the college's "Professional Obligations and Human Rights" is adopted, then if doctors refuse to refer patients to abortionists, or to doctors willing to prescribe contraceptives, they could face disciplinary action.

"If there were a complaint, every complaint is investigated by the complaint committee," Dr. Gabel said. The complaint committee could deliver a mild private rebuke or turn over the matter to the disciplinary committee, which Gabel chaired for several years.

According to Dr. Carol Leet, the new president of the college, a doctor found guilty of professional misconduct by the disciplinary committee could face anything from remedial instruction to loss of his or her medical licence.

Weatherbe S. "Doctors who oppose abortion should leave family medicine: Ontario College of Physicians." LifeSite News, 19 December, 2014. (Accessed 2014-12-21)

2.    The following report was based upon a tape-recorded interview with Dr. Gabel. He has never denied its accuracy.

Catholic doctors who won't perform abortions or provide abortion referrals should leave family medicine, says an official of the College of Physicians and Surgeons of Ontario.

"It may well be that you would have to think about whether you can practice family medicine as it is defined in Canada and in most of the Western countries," said Dr. Marc Gabel, chair of the college's policy working group reviewing "Professional Obligations and Human Rights."

Gabel said there's plenty of room for conscientious Catholics in various medical specialties, but a moral objection to abortion and contraception will put family doctors on the wrong side of human rights legislation and current professional practice.

Swan, M. "Catholics doctors who reject abortion told to get out of family medicine." The Catholic Register, 17 December, 2014. (Accessed 2014-12-19)

3.  Interviewed in anticipation of the Supreme Court ruling in Carter v. Canada, Dr. Gabel did not deny this.

Whatever its policy ultimately looks like, the college is clear: a patient's right to access services outweighs a doctor's right to refuse them. "We prioritize the interests of our patients in facilitating access," says Dr. Marc Gabel, past president of the college and chair of the policy's working group.

Nasser S. "If Supreme Court decriminalizes physician-assisted suicide, doctors may be obligated to help with euthanasia." National Post, 4 February, 2015 (Accessed 2015-02-17).

4.  Marshall P, Robson R.  "Conflict Resolution."  Royal College of Physicians and Surgeons of Canada. (Accessed 2015-02-17)

5.  Gabel, M. "Dear Colleagues." College of Physicians and Surgeons of Ontario, Dialogue, Vol. 10, Issue 4, 2014, p. 6. (Accessed 2015-02-02).

6.  College of Physicians and Surgeons of Ontario, Council Briefing Note: Professional Obligations and Human Rights - Draft for Consultation (For Decision) (December, 2014). In Annual Meeting of Council, December 4-5, 2014, p. 329.

7.  College of Physicians and Surgeons of Ontario, Council Briefing Note: Professional Obligations and Human Rights - Draft for Consultation (For Decision) (December, 2014). In Annual Meeting of Council, December 4-5, 2014, p. 329-330.

8.  College of Physicians and Surgeons of Ontario,  Council Briefing Note: Professional Obligations and Human Rights - Draft for Consultation (For Decision) (December, 2014).  In, Annual Meeting of Council, December 4-5, 2014, p. 328

9.  College of Physicians and Surgeons of Ontario, Physicians and the Ontario Human Rights Code Consultation, Online Survey Report and Analysis, Table 1.

10.  College of Physicians and Surgeons of Ontario, Council Briefing Note: Professional Obligations and Human Rights - Draft for Consultation (For Decision) (December, 2014). In Annual Meeting of Council, December 4-5, 2014, p. 326.

11. It is possible that details were disclosed to Council members when POHR was discussed.  The meeting appears to have been conducted in camera. College of Physicians and Surgeons of Ontario, Annual Meeting of Council, December 4-5, 2014, Revised Agenda.

12.  Nasser S. "If Supreme Court decriminalizes physician-assisted suicide, doctors may be obligated to help with euthanasia." National Post, 4 February, 2015 (Accessed 2015-02-17).

13.  Marshall P, Robson R.  "Conflict Resolution."  Royal College of Physicians and Surgeons of Canada. (Accessed 2015-02-17)

14.  Marshall P, Robson R. "Conflict Resolution." Royal College of Physicians and Surgeons of Canada. (Accessed 2015-02-19)

15.  Letter from Dr. Mark Hobart to Mr. Edward O’Donohue, Chairperson, Scrutiny of Acts and Regulation Committee, Parliament of Victoria, dated 7 June, 2011. (Accessed 2015-02-19)

16.  Rolfe P. "Melbourne doctor’s abortion stance may be punished." Herald Sun, 28 April, 2013 (Accessed 2015-02-19)

17.  Devine M. "Doctor risks his career after refusing abortion referral." Herald Sun, 5 October, 2013 (Accessed 2015-02-19)

18.  Personal communication between Dr. Mark Hobart and the Administrator, Protection of Conscience Project, 19 February, 2015 (20 February, 2015 in Australia).

19.  Cook H. "Abortion law changes eyed as Dr Mark Hobart probed." The Age, 7 November, 2013 (Accessed 2015-02-19)

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