1
2
TABLE OF CONTENTS
1. INTRODUCTION.....................................................................................................................4
2. MEANING OF SURROGACY.................................................................................................4
3. TYPES OF SURROGACY.......................................................................................................5
4. HISTORY OF SURROGAC.....................................................................................................6
5. PRESENT SCENARIO OF SURROGACY IN INDIA............................................................8
6. LAW COMMISSION REPORT...............................................................................................9
7. SURROGACY (REGULATION) BILL, 2019.......................................................................10
7.1. FEATURES OF SURROGACY (RGULATION) BILL, 2019.......................................11
7.2. MERITS AND DEMERITS OF THE SURROGACY (RGULATION) BILL, 2019.....12
7.3. KEY ISSUES TO CONSIDER........................................................................................13
8. ASSISTED REPRODUCTIVE TECHNOLOGY (REGULATION) BILL, 2020..................14
9. PROS AND CONS OF SURROGACY..................................................................................14
10. JUDICIAL PRONOUNCEMENTS........................................................................................15
11. SUGGESTIONS......................................................................................................................16
12. CONCLUSION........................................................................................................................17
13. REFERENCES........................................................................................................................18
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INTRODUCTION
The practice of surrogacy in India is carried out from centuries to help those couples who are not
able to conceive a child due to natural reasons such as infertility, age factor, same sex couple etc.
India has emerged as the main surrogacy destination since it legalized commercial surrogacy in
2002. It was done primarily for two reasons. First, surrogacy procedure is at very low cost in
India. The complete package costs just one-third of the total procedure cost in the developed
countries like UK. Second, the legal environment here is much favorable. In fact, there is no law
as such to govern matters related to surrogacy in India. The Artificial Reproductive Technique
(ART) Bill, 2008, is pending since 2014 and has been revised twice.
A surrogacy procedure is a legal arrangement in which a woman agrees to carry pregnancy for
the intended parents. The government realized the need of regulating the surrogacy practice in
India to protect the interests of every party involved in the procedure of surrogacy and imposing
reasonable restrictions. Then, The Surrogacy (Regulation) Bill, 2019 was introduced by the
Ministery of Health and Fmaily Welfare to regulate the surrogacy procedure in India.
MEANING OF SURROGACY
The word ‘surrogacy’ means ‘substitution’ or ‘replacement’. A ‘surrogate woman’ is also known
as ‘surrogate mother’. Surrogacy is a method by which a couple who cannot have their child
naturally take the help of another woman to carry their chid for them. An embryo is implanted in
the womb of the surrogate mother following in vitro fertilization (IVF). Once the embryo and
sperm has been implanted in the womb of surrogate mother and thereafter the pregnancy is
confirmed, the surrogate women has to undergo regular checkups to ensure that the child is
maturing properly. Delivery is performed in the same manner as other pregnancy is performed
and then the resulting child is given to the intended parents.1
The most common reason for surrogacy is that it fulfills one’s desire to have their own genetic
child and it also replaces the option of adoption to the infertile couples. Surrogacy may also be
performed due to natural or medical constraints or any other reason which makes the carrying of
pregnancy or delivery risky. Sometimes the commissioning women is fertile and healthy and still
1
[Link]
4
prefers that someone else carry the pregnancy on behalf of her to avoid the risk of pregnancy be
her.
Surrogacy also provides an opportunity to same sex couples to have their own child and fulfill
their dream of becoming parents. It also provides an opportunity to the single person to have
their own child.
TYPES OF SURROGACY
Surrogacy can be classified by two categories which are as follows:
a) ON THE BASIS OF SCIENTIFIC METHOD APPLIED
a) Traditional surrogacy:
Traditional surrogacy is also known as ‘partial surrogacy’. Traditional surrogacy is a
process through which a surrogate mother is artificial inseminated by the
commissioning father. The child can be conceived through natural insemination or
artificial insemination. The artificial insemination can be done at home or at the lab
using fresh or frozen sperms or IUI (Intrauterine Insemination). Traditional surrogacy
is also called as ‘straight method’.
In traditional surrogacy half of the genetic material for the child is given by the
surrogate mother. This was the only method available for surrogacy before the
advancement of IVF technique or any other fertility treatment.
Traditional surrogacy has lost its popularity in recent times due to the advancement in
medical procedures and legal rulings and it is found to be more complicated.
b) Gestational surrogacy
Gestational surrogacy is also called full surrogacy. It is a modern method of
surrogacy as it depends upon IVF technology. Gestational surrogacy is a process
where a genetic material are taken and combined in a lab setting and then it is
implanted in the womb of surrogate mother through IVF procedures. A donated
genetic material can be used in the cases where on of the parent cannot provide a
genetic material. This process is becoming the golden standard of all types of
surrogacy procedures
5
Advancement in technology has allowed that any genetic material provided for IVF
process to be screened for possible genetic anomalies or diseases. This is known as
Preimplantation Genetic Diagnosis (PGD).Gestational surrogacy is also known as
Host method.
b) ON THE BASIS OF THE VALUE IT HOLDS
a) Altruistic surrogacy
Altruistic surrogacy is also known as free surrogacy. In altruistic surrogacy the
surrogate mother is not given any financial reward or fee for carrying the child of the
intended parents. However, all the expenses are paid by the intended parents
regarding pregnancy and delivery of the baby. It deals with the criteria of affection
and care as consideration. Generally, in altruistic surrogacy, a surrogate mother is the
closest relatives or friends of the intended parents.2
b) Commercial surrogacy
Commercial surrogacy is also called paid surrogacy. It is type of surrogacy in which
the surrogate woman is hired and paid for carrying the child of the intended parents in
their womb. Commercial surrogacy became popular because of the following reasons
such as excellent medical infrastructure, high international demands, unregulated
laws till date and ready availability of poor surrogates. However, commercial
surrogacy is criticized on the following grounds that it represents selling of baby as a
‘product’ and it is also charged with a lot of emotional, moral and ethical issues.
HISTORY OF SURROGAC
The roots of surrogacy can be traced back in ancient times. However, in recent times it has been
recognized as a treatment for infertility. We can see the occurrences of surrogate pregnancies in
mythological epic also. In recent times, the advancement of medical science and technology has
brought various changes in the area of surrogacy.
The historical background of surrogacy is divided into three parts:
a) Ancient Period
2
Charushila , “Surrogacy -- A Hope”, [Link] [Link]
6
b) Medieval Period
c) Modern Period
ANCIENT PERIOD
The mythological epic has shown the occurrences of surrogacy. In Mahabharata, the King Kansa
has locked his sister Devaki and her husband Vasudeva in the prison due to the prediction of his
death by the eighth son of his sister Devaki. The King Kansa killed six new born baby of his
sister. It also describes that Devaki had miscarriage of his seventh son Balram, who in reality
was secretly transferred to the womb of Rohini by the will of God. As per Bhagwad Gita, Lord
Krishna was born without sexual union and was conceived by the divine ‘mental transmission’
from the mind of Vasudeva into the womb of Devaki.3
In Mahabharata, it is also believed that Gandhari, the wife of King Dhritarashtra who had
conceived had a prolonged pregnancy for nearly two years. Then Bhagwan Vyasa said that
Gandhari had delivered a mass of material that contained 101 normal cells, which after being
kept into a nutrient medium to grow them up full term as a hundred male children called the
Kauravas, and one female child called Dusheela.
Again, in Mahabharata, Kunti conceived her eldest son Karna through the Sun God. When Kunti
was very young, had an opportunity to serve Rishi (sage) Durvasha. She looked after him with
great dedication. Rishi Durvasha pleased by her dedication, gave her a mantra and said that after
reciting this mantra whichever God she would think of, that God would appear before her and
will bless her with a son.
In Ramayana, the King Dashrath was unable to impregnate any of his three wives. Then he seeks
the help of a Sage, who gave him some ‘kheer’ (rice pudding; probably a euphemism for sperm
in a holy text book) which he gives it to one of his wives to distribute equally among them and
thereafter all three wives get pregnant and he becomes the father of four sons.
These examples shows the existence of surrogacy in India in an untitled form and whereas now it
is termed as surrogacy be the scientist technology. It can also be said that, in ancient times it was
the magical power of God and now it is the power of science and technology.
3
Gehna Vaishnavi, Navneet Tatkkar ‘
Surrogacy Medicolegal Issues,’ Jaypee Medical Health Publisher, New Delhi, 2015, 1st Edn., at p.8.
7
MEDIEVAL PERIOD
In medieval period, with the advancement of medical science and technology, in vitro
fertilization (IVF) technique was introduced for the Indian childless couples. This technique
became successful practice in India with the birth of India’s first and world’s second IVF baby
Kanupriya Alias Durga, born in Kolkata on October 3, 1978 and the credit goes to Dr. Subhash
Mukhopadhyay for brining India’s first IVF baby.
But instead of recognizing his achievement Dr. Mukhopadhyay was charged as an accused
before the expert committee which called on 18th November, 1978 to decide whether his
innovation could fight the infertility?4
After 27 years of his death, the Indian Council of Medical Research (ICMR) has recognized his
contribution as a creator of India’s first test tube baby and even the international scientific
community also accepted Dr. Subhash Mukhopadhyay achievements by enlisting his name as a
medical scientist in the ‘Dictionary of Medical Biography’
MORDERN PERIOD
In the modern period there is a remarkable development in assisted reproductive technology,
and there is a huge use of surrogacy by the infertile couples. The latest innovation in the assisted
reproductive technology is that the now the world is moving from assisted reproduction towards
artificial reproduction. Today, the use of surrogacy is not only limited to infertile couples, but
also providing an opportunity to single person, homosexuals and transgender also.
PRESENT SCENARIO OF SURROGACY IN INDIA
Commercial surrogacy was made legalized in the year 2002 in India. After this the new word
comes into picture that is ‘rent a womb’. This was done to promote medical tourism in India.
After this decision India became the hub of surrogacy.
Main reason being low cost in India (it costs up to 70 to 80 lakhs and in the absence of a strict
legislation. According to a CII report of 2012 the business of surrogacy industry in India is more
than $400 million (29,31,60,00,000 Indian Rupee) a year. It was estimated that more than 3,000
fertility clinics were engaged in the business of surrogacy across the country.
4
Gehna Vaishnavi, Navneet Tatkkar ‘Surrogacy Medicolegal Issues,’ Jaypee Medical Health Publisher, New Delhi,
2015, 1st Edn., at p. 10.
8
However, the unregulated business of surrogacy led to following issues:
1. Unethical practise,
2. Middlemen and commercial agencies are most profited,
3. Exploitation of surrogate mothers,
4. Abandonment of children born out of surrogacy,
5. Rackets of organ trade, embryo import etc.,
6. This called for a legislation to regulate surrogacy in the country.
LAW COMMISSION REPORT
Law commission of India highlighted in their report that there is a needed to enact a law to
regulate the matters of surrogacy. In its 228th report, Law Commission of India recommended the
ban commercial surrogacy and allow only for altruistic surrogacy in India.
The following reasons were stated by Law Commission of India:
1. Ban use of surrogacy for foreigners,
2. There is a lack of a proper legal framework to regulate the matters of surrogacy,
3. Exploitation of the surrogate mother who may have been coerced to become a surrogate
due to poverty and lack of education.
Law Commission of India recommended important points which are as follows:5
1. A contract for surrogacy should be made which should contain all the requirements like
consent of the surrogate mother and consent of her family members that she can bear the
child, the medical expenses for her and the child should finally be hand over to the
intending parents. The contract should not be for the commercial purposes.
2. financial arrangements should be made for the child who had been born by surrogacy, if
there occurs the death of the intending parents or any individual who was bearing the
child or the divorce between the couples and nobody is willing to take the child.
3. Contract for surrogacy should cover the life insurance of the surrogate mother.
4. One of the commissioning parents should also be a donor so that there is a genetic
relation between parents and child, which will be born out of surrogacy.
5
[Link] › ...PDF Web results GOVERNMENT OF INDIA LAW COMMISSION OF INDIA
Report No. 228.
9
5. Surrogate child should be a legal child of the commissioning parents without declaration
of guardians or by adoption of him/her.
6. The name of the commissioning parents should be imprinted on the birth certificate of the
surrogate child.
7. There should not be any violation of Right to Privacy of the donor as well as of the
surrogate mother.
8. There should be prohibition of sex selective surrogacy.
In 2013, a notification was issued by the government prohibiting surrogacy for the foreign
homosexual couples and single parents. In 2015, the commercial surrogacy was banned by the
government in India and allowed entry of embryos only for research purposes.
In the year 2016, a Surrogacy (Regulation) Bill was introduced and passed in Lok Sabha. The
Bill proposes to allow only homosexual Indian couples who are married for at least five years
having infertility problem, to access altruistic or unpaid surrogacy and proposes to ban
commercial surrogacy. The 2016 Bill lapsed after parliament was dissolved. The bill was
reintroduced and passed by Lok Sabha on December 19, 2018. this bill states some rules to
control surrogacy in the country and completely banned the commercial surrogacy and permitted
for only altruistic surrogacy.
SURROGACY (REGULATION) BILL, 2019
The Surrogacy (Regulation) Bill, 2019 was introduced and passed in Lok Sabha and the Bill is
pending as it need to be passed in Rajya Sabha and presidential assent to become an Act.
FEATURES OF SURROGACY (RGULATION) BILL, 2019
1. The central government should constitute National Surrogacy Board at national level 6 and
state government should constitute State Surrogacy Board at state levels.7
2. It prohibits commercial surrogacy and allows only ethical altruistic surrogacy.8
3. The Bill permits surrogacy under following circumstances which are as follows:9
a) The intending couple is suffering from infertility,
b) It should be altruistic surrogacy,
6
Section 14 of The Surrogacy (Regulation) Bill, 2019.
7
Section 23 of The Surrogacy (Regulation) Bill, 2019.
8
Section 5 of The Surrogacy (Regulation) Bill, 2019.
9
Section 4(ii) of The Surrogacy (Regulation) Bill, 2019.
10
c) It should not be for commercial purposes,
d) It should not be for producing children for sale, prostitution of for any other forms of
exploitation,
e) It should be for any other condition or disease as prescribed by the regulation.
4. Eligibility criteria for intending couple:10
a) That they should be an Indian citizen and should be married for at least 5 year,
b) Wife’s age should be between 23 to 50 years old and husband’s age should be 26 to
55 years old,
c) They have to provide a ‘certificate of essential’ and also a ‘certificate of eligibility’,11
d) The intending couple also have to undertake that they will not abandon the child born
out of surrogacy.
e) The Intending couple should not have any surviving child, except if the child is
mentally or physically challenged or is suffering from any life-threatening disorder,
f) Other conditions as specified by the regulation.
5. Eligibility criteria for surrogate mother:12
a) She should be s close relative of an intending couple,
b) She should be ever married woman having her own child,
c) Her age should be between 25 to 35 years old,
d) There should be no previous surrogacy,
e) A certificate of medical and psychological fitness for surrogacy from a registered
medical practitioner.
6. Surrogate mother shall have insurance coverage for some time to cover not only the
period of pregnancy but after that also.13
7. A surrogate mother cannot provide her own gametes for the method of surrogacy.14
8. The Bill seeks to regulate the functioning of surrogacy clinics in India.15
9. All surrogacy clinics in the country need to be registered.16
10
Section 4(iii)(c) of The Surrogacy (Regulation) Bill, 2019.
11
Section 4(iii)(a) of The Surrogacy (Regulation) Bill, 2019.
12
Section 4(iii)(b) of The Surrogacy (Regulation) Bill, 2019.
13
Section 4(iii)(a)(III) of The Surrogacy (Regulation) Bill, 2019.
14
Section 4(iii)(b)(III) of The Surrogacy (Regulation) Bill, 2019.
15
Chapter IV of The Surrogacy (Regulation) Bill, 2019.
16
Section 10 of The Surrogacy (Regulation) Bill, 2019.
11
10. It also specifies that no sex selection can be done in surrogacy.17
11. The child born out of surrogacy method will be considered the biological child of the
intending couple.18
12. Certain offences have been recognized under Bill, which attracts the penalty of 10 years
imprisonment and a fine of up to 10 lakh rupees.19 These offences are as follows:
a) Undertaking or advertising commercial surrogacy,
b) Exploitation of the surrogate mother,
c) Selling or importing human embryo or gamete for the surrogacy,
d) Abandoning, exploiting or disowning of a child born out of surrogacy.
MERITS AND DEMERITS OF THE SURROGACY (RGULATION) BILL, 2019
MERITS OF THE BILL
1. Preventing the exploitation of women
2. The rights of the surrogate mother are ensured
3. Better health and life of the surrogate mother
4. Proposes punishment
5. There is a proper procedure for the adoption of the child who has been iabandon by the
intended parents.
DEMERITS OF THE BILL
1. Disqualifying on the basis of nationality, marital status,sexual orientation or age is
against the right to equality.
2. The right to life includes the right to reproductive and right to parent hood. So that the
state should not decide the modes of parenthood
3. Sudden interruption of the government would just push the dollar million market industry
underground. Thus, the very purpose of the bill to protect surrogate mothers from
exploitation would be defeated.
4. Fertility specialists and attached business would suffer.
5. Commissioning mothers who are carrying a child would be left in a limbo
6. Restricting only a blood relative to be a surrogate mother is illogical and unreasonable.
17
Section 3(viii) of The Surrogacy (Regulation) Bill, 2019.
18
Proviso of section 7 of The Surrogacy (Regulation) Bill, 2019.
19
Chapter VII of The Surrogacy (Regulation) Bill, 2019.
12
KEY ISSUES TO CONSIDER
The Surrogacy (Regulation) Bill, 2019 does not take into consideration the following issues:
1. Is complete ban of surrogacy viable?
2. There are high possibilities that underground operations for surrogacy be done.
3. Infertility is one of the important conditions that has to be proven by an intending couple
to be eligible for surrogacy. It does not cover all cases in which a couple is unable to bear
a child. Medical condition of the couple ha to be revealed.
4. The Bill specifies various eligibility conditions to be fulfilled by the couples intending to
undertake surrogacy and allows NSB to specify additional conditions to be fulfilled by
the intending couple. This is the excessive delegation of the legislative power.
5. Bill does not provide for a review or appeal procedure in the cases where surrogacy
applications are rejected.
6. The Bill does not define the term ‘close relative’.
7. Bill states that, approval of appropriate authority is mandatory for abortion to be done by
the surrogate mother and approval must comply with the provisions of Medical
Termination of Pregnancy Act, 1971. However, Bill does prescribes the time period by
which such approval for abortion has to be given.
8. The Bill does not specify about the maternity relief to the surrogate mother.
9. Why should not women get the right to choose if they want to rent their womb? Article
14 and 21 of the Indian Constitution
10. The Bill does not talk about same sex couples.
11. LGBTQ community is now accepted to be a part of the mainstream after section 377
scrapped. They also have the right to become parents.
12. Presumption that surrogate mother was compel to be a surrogate and burden of proof lies
on the parties that they did not compel the surrogate mother to be a surrogate.
13. Storage for embryo or gamete for surrogacy not allowed.
ASSISTED REPRODUCTIVE TECHNOLOGY (REGULATION) BILL, 2020
Assisted Reproductive Technology (ART) is used for the treatment of infertility. ART includes
fertility treatment that includes both man’s sperm and woman’s egg. It works by removing eggs
13
from a woman’s body and mixing them with man’s sperm for making embryos. The embryos are
then put into the surrogate woman’s body.
IVF is most common type of ART.
The aim of the Bill is to regulate the functioning of ART banks and clinics and allow the safe
and ethical practice of ART’s and protect the women and children from being exploited.
This Bill was introduced to supplement the Surrogacy (Regulation) Bill, 2019. According to the
committee, a mere enactment of the Surrogacy (regulation) Bill, 2019 would not alone serve the
purpose to control commercial surrogacy in India as surrogacy procedures cannot be conducted
without ART’s.
PROS AND CONS OF SURROGACY
PROS OF SURROGACY
1. It fulfills the wish of the couples to complete their family.
2. It is the alternate method for the woman who is suffering from infertility issues due to
certain reasons.
3. It is the method through which one can fight against the infertility.
4. The child possesses the genes of the intending parents so that there is genetic relation
between the
5. intending parents and the surrogate child.
6. It is better a option than adoptions because adoption process takes a lot of time and
includes a huge paper work and the psychology of the child with the couples. Sometimes,
it takes some years to complete all the formalities to adopt the child.
7. Women have the positive experience by helping the peoples to have their own child.
8. Commercial surrogacy helps the poor women in getting money to meet her own needs
and the money can also be used to fulfill the needs of their own child/children or their
families or for future purposes
9. Any person can have the privilege of having their own child whether they are couples,
lesbian, gay or single person.
10. The birth and the death ratio of the child in the country improves.
CONS OF SURROGACY
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1. Surrogacy may be treated like prostitution.
2. There can be exploitations of the women regarding the surrogacy for the money.
3. Women are treated as a labour which provides the facilities for the birth of the child.
4. If both the commissioning parents and surrogate mother refuses to keep the child, then
there will be the violation of rights of the child.
5. Only the wealthy people can afford surrogacy.
JUDICIAL PRONOUNCEMENTS
In Baby Manji Yamada v. Union of India, 20 a child who was born in India to a surrogate mother
for a Japanese couple. The Japanese couple separated a month before the birth of the child. The
Japanese father want to take the child with him to Japan but due to lack of legal framework on
such regard in Japanese law restricted the travel of child to Japan. The SC of India decided the
matter allowing the grandmother to take the child with her. Japaneses government issued visa for
one year to her on humanitarian grounds.
In Jan Balaz v. Anand Municipality and Ors.,21 the Gujrat HC conferred Indian Citizenship on
two twin babies fathered through compensated surrogacy by a German National in Anand
District. The court observed: "We are primarily concerned with the rights of two newborn,
innocent babies, much more than the rights of the biological parents, surrogate mother, or the
donor of the ova. Emotional and legal relationship of the babies with the surrogate mother and
the donor of the ova is also of vital importance.” In May 2010, the Balaz twins were provided the
exit and entry documents that allowed them to leave India for Germany. The parents agreed to
adopt them in Germany according to German rules.
In R. Rajgopal v. State of Tamil Nadu, 22 the court held that the ‘right to life’ includes ‘right to
privacy’. An individual has the right to decide over matters such as family, marriage,
procreation, motherhood, childbearing among other things.
In B.K. Parthasarthi v. Government of Andhra Pradesh,23 the court held that the right over
decision of reproduction falls with the right to privacy. The right over control of the body on
reproductive matters is the personal choice of the individual.
20
Judgement on 29 September, 2008.
21
Judgement on 11 November, 2009.
22
1994 SCC (6) 632.
23
2000 (1) ALD 199.
15
In Justice K.S. Puttaswamy v. Union of India, 24 the court ssaid that the reproductive choices of
the women is their constitutional right citing personal liberty under Article 21 of the Constitution
of India.
SUGGESTIONS
The following suggestions are as follows
1. The rights of the surrogate mother must be protected in every possible manner,
2. A proper contract should be made between the intending parents and the surrogate
mother to avoid the anomalies and also to protect the rights of the child.
3. The contract should also mention contain the details of the second legal parent if some
problems arises with the first parent.
4. The commissioning parents must be the legal parents of the child.
5. The nationality of the child should not be affected in any way and should be same as that
of the commissioning parents.
CONCLUSION
Surrogacy is defined as, when other woman carries the child in her womb, of the couples who
are unable to produce themselves. Tit provides happiness to the couples and complete their
family by having their own child. In India all forms of surrogacy are allowed but did not get any
legal status. But in 2008, through baby Manji Yamada case 25, the SC opens the door for legal
status of surrogacy in India.
The Surrogacy (Regulation) Bill, 2019 was introduced and is pending in the parliament. It bans
commercial surrogacy in India as India has become a surrogacy hub and also has resulted in
exploitation of surrogate mother and abonnement of the surrogate child. The Bill allows only for
altruistic surrogacy. This Bill has faced various challenges as some issues are not considered in
this Bill.
The Assisted Reproductive Technology (Regulation) Bill, 2020 was introduced with the aim to
regulate surrogacy clinics in the country and to have safe and ethical surrogacy. It was
introduced to supplement the Suurogacy (Regulation) Bil, 2019.
24
Judgement on 26 September, 2018.
25
Judgement on 29 September, 2008
16
REFERENCES
STATUTE:
1. The Surrogacy (Regulation) Bill, 2019.
2. The Assisted Reproductive Technology (Regulation) Bill, 2020.
WEBSITES:
1. [Link]
2. [Link]
3. [Link]
4. A Critical Analysis of The Surrogacy (Regulation) Bill, 2019 - iPleaders
5. [Link]
6. [Link]
without-art-bill-committee-to-rajya-sabha/articleshow/[Link]?from=mdr
7. [Link]
8. [Link] ([Link])\
9. surrogacy: Surrogacy Bill useless without ART Bill: Committee to Rajya Sabha - The Economic
Times ([Link])
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