some cases, procedures required to protect a woman's life were not available during pregnancy. A prime example would be cancer treatments such as chemotherapy which would do extensive and irreversible harm to an embryo or foetus if done during pregnancy but which, if not done in a timely fashion, can allow the cancer to spread to a point at which the condition is fatal and no longer successfully medically treatable. These were the cases which the TAC's were originally intended to address, but many hospitals were unwilling to perform abortions at all. No requirement for hospitals to provide abortions Hospitals had Therapeutic Abortion Committees only if they opted to provide abortions, and there was and is no requirement that they do so. As well, the requirement for three doctors to sit on a committee, in addition to the doctor who proposed to perform an abortion, meant that abortions were only available in hospitals where there were four doctors familiar with the procedure. Net effect of the law The end result was a very limited access to lawful abortion which varied widely from one town or province to another. Many towns and cities did not have any hospital that provided abortions. Supreme Court rules the provisions are unconstitutional In 1988, a case involving Morgentaler reached the Supreme Court of Canada. The court ruled that the provisions relating to abortion were contrary to section 7 of the Canadian Charter of Rights and Freedoms. Although there was no single majority judgment, the three judgments finding the provisions unconstitutional concluded that the delays and limited access to abortion inherent in the system of Therapeutic Abortion Committees violated the right to security of the person of a woman seeking an abortion. The delays and limited access potentially had a profound impact on a woman's health and thus infringed her rights to liberty and security of the person, contrary to section 7 of the Charter. The court held that this section of the Criminal Code was unconstitutional and inoperative. The effect of the decision was that abortion was decriminalized in Canada. Senate rejects attempt to re-criminalize Following the Supreme Court decision, the Progressive Conservative government of Prime Minister Brian Mulroney explored legislative options in response to the decision. In 1990, a compromise bill, Bill C-34 passed the Commons. Similar to the previous requirement for approval by a TAC, it would have required the consent of one