Christian Scholars Review (Fall, 1971) 42-58.

      Copyright © 1971 by Christian Scholars Review. Cited with permission.

 

 

     In this essay, C. E. Cerling, Jr., a United Methodist clergyman,

     re-examines abortion and contraception in the light of biblical

     revelation.

 

      Abortion and Contraception in Scripture

 

                                                  C. E. Cerling

 

            THE PURPOSE of this paper is the examination of the biblical

teaching relating to the problems of abortion and contraception. This exam-

ination it is hoped will provide a necessary foundation for discussions of the

problems in the ethical realm, particularly the problem of whether abortion

is equivalent to murder. Before one can consider the problems in terms of

specific situations it is necessary to establish general principles that can be

applied to all situations.1 By focusing attention on the problems of overpopula-

tion, poverty, and other matters relating to these problems, one moves from the

area of theology to situation-dominated ethics.2

            Is it fair to ask of documents as old as the Bible questions concerning

abortion and contraception, questions that appear to have such modern origins?

The questions are fair, because they are not really questions unique to the

present age. Noonan,3 who gives the most thorough discussion of the early

Church's attitude toward contraception as it developed historically,4 devotes

 

   1 Helmut Thielicke, The Ethics of Sex, trans. J. W. Doberstein (New York: Harper and

Row Publishers, 1964), p. 232 states that ethical principles may even present situations

where a principle is more important than a life. But he also affirms the importance of

difficult cases to test one's ethic (p. 199).

    2 J. W. Montgomery, "How to Decide the Birth Control Issue," Christianity Today X

(March 4, 1966), 9. William E. Hulme, "A Theological Approach to Birth Control," Pastoral

Psychology XI (April, 1960), 26-7. It should also be added that these secondary considera-

tions may force re-examination of one's original position because of factors not considered

in scripture because not applicable to the biblical mileau.

    3 J. T. Noonan, Jr. Contraception: A History of Its Treatment by the Catholic Theolo-

gians and Canonists (Cambridge: Harvard University Press, 1965), chapter one.

    4 Noonan writes from the Catholic perspective, but since much of the teaching of the

Church is the teaching of the Catholic Church during the early years of development,

treatment from the Catholic perspective is valid. See also Lloyd Kalland, "Views and

Positions of the Christian Church--An Historical Review," Birth Control and the Christian,

eds. Walter 0. Spitzer and Carlyle L. Saylor (Wheaton: Tyndale House Publishers, 1969),

417.

                                                                        42

 



                                    Cerling: Abortion and Contraception                      43

 

much of his first chapter to a discussion of methods of contraception and

abortion in the ancient world. Whole treatises were written on the topics in

cultures having intimate contact with the children of Israel.5

            A paper on the biblical teaching on birth control automatically excludes any

discussion of birth control for the unmarried. The Bible never entertains the idea

that sexual intercourse apart from the marital relationship is justified (Ex.

20:14; I Cor. 6:13-20). For this reason the morality of birth control for the

unmarried is like the question of whether a bank robber should use a Ford or a

Plymouth as his getaway car. The more important question is whether he should

ever rob a bank. The question of birth control for the unmarried is also a

question of protection in sin, a question never raised.

            The question of abortion for the unmarried poses a different problem.

Abortion for those involved in pregnancies induced by rape or forced incest and

those women whose health would be endangered or who may produce a

genetically damaged child should be considered under the sections dealing

generally with abortion. This discussion, though, will also not consider the

problems involved in the pregnancies of women who have co-operated in illicit

intercourse, except for cases covered by the problems stated above. Unmarried

women involved in illicit intercourse are not a subject for this study for the same

reasons as given in the preceding paragraph concerning contraception and the

unmarried.

 

THE DEVELOPMENT OF THE CHRISTIAN POSITION

ON CONTRACEPTION AND ABORTION6

            One cannot discuss the biblical teaching on contraception without consid-

ering at the same time the teaching of the Church and its development.7

Traditional teaching needs to be understood in the light of scripture (sometimes

misunderstood), the philosophical climate, the religious climate, and current

medicinal practices.8 For example, Paul writes in Romans 1:26-7 of "unnatural

 

   5 See below pp. 48-49.

   6 Noonan, Contraception .... ch. one, on whose work this section is based, treats the

development of the Catholic Church's teaching from the dawn of the Church age until the

modern era.

In this paper the patristic material is examined first because it shows the source of many

present day attitudes. We can also see how and to what the fathers reacted in forming their

teaching to see if our teaching should be formed through the interaction of scripture and

ideas similar to those of the fathers.

     Since the I.U.D.'s status as contraceptive or abortifacient is still being debated, further

medical research needs to establish where it should be included.

   7 Generalizations about the Church do not indicate that the author thinks all churchmen

agreed on a given position. What is assumed is that the majority of people writing on a topic

agreed on a basic core of teaching that can be fairly called the teaching of the Church.

    8 Noonan, ch. two.

 

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44                                Christian Scholar's Review

 

acts." The early Church fathers thought that "natural" was the obvious function

of an act; they thought the function of sexual relations that is most natural is

the procreation of children.9 This view is now considered a misinterpretation,

but it was used to develop the view of sex that dominated the Church for almost

two thousand years.

            Current medical practice also affected the development of early Church

teaching. Contraception and abortion were treated together because of the

difficulty of differentiating them in the early stages of pregnancy.10 Many of

the contraceptive methods used were powerful enough to cause an abortion in

the early stages of pregnancy. By combining this difficulty with the known fact

that abortion and contraception were frequently connected with the work of

magicians,11 it is easier to understand why the Church condemned such prac-

tices.

An interpretative principle that one can occasionally see operating in the

Church also played a part in the development of the early Church's teaching; this

is the principle of maximization. Maximization occurs when a weak or easily

misunderstood passage is explained and used as the basis for a strong stand on a

controversial subject. The interpretation of Genesis 38 (Onanism) is an example.

A passage that is not clear was used to condemn contraception.12

The patristic age generally had a pessimistic view of marriage.13 It would

appear that the Church fathers took I Corinthians 7 to heart without the

corrective of Ephesians 5. This low view of marriage, combined with the above

interpretation of Romans 1:26-7, resulted in a view of sex that was purely

functional; therefore intercourse is frequently condemned if it is primarily for

pleasure. Since the act is functional, and contraception would interfere with that

function, one would only use contraception if one wanted to engage in sex

relations for pleasure--something strongly condemned. And if pleasure were not

one's intention, covetousness could be the only other reason for prohibiting

children, because limiting the size of one's family would be economically

advantageous, and covetousness is also wrong.

Abortion was equated with murder very early in the patristic period. In its

explanation of the "Two Ways" the Didache represents abortion as murder along

 

   9 Ibid., pp. 74-5. This view was held even through the 19th century. Herschel Wilson

Yates, Jr. "American Protestantism and Birth Control," (unpublished Ph.D. dissertation,

Harvard University, 1968), ch. three.

    10 Noonan, p. 17.

    11 Ibid., p. 17.

    12 Other passages used in this way are Romans 1:26-7 and I Thess. 4:4. An example more

familiar to most people would be the maximization that has taken place in the Roman

Catholic Church with regard to Jesus' statement to Peter at Caesarea Philippi. This passage is

weak and easily misunderstood as support for papal infallability, but it is used to justify it.

    13 Derrick Sherwin Bailey, Sexual Relation in Christian Thought (New York: Harper and

Brothers, 1959), p. 24.

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Cerling: Abortion and Contraception                      45

 

with the exposure of infants.14 This is readily understandable if one reads the

septuagint translation (really rewording) or the Hebrew of Exodus 21:22-2315

where accidental abortion is punished by the death penalty. Naturally, if

accidental abortion deserves death, then intentional abortion should deserve no

lesser punishment.

The Jewish understanding of the purpose of intercourse may also have

influenced the Church fathers. The Halakah consistently interprets Genesis 1:28

as a command to have children.16 A functional understanding of intercourse is

also seen in Philo, who expressly condemns intercourse that is not specifically

for procreation.17 With such an attitude current in rabbinic and Philonic

Judaism it is not surprising that the Church fathers (Clement, Justin, Origen,

Chrysostom, Ambrose, and Jerome to name a few) similarly viewed intercourse.

Noonan, speaking of the development of the early Church's understanding

of the purpose of intercourse, writes:

 

The construction was not a purely theological enterprise. It was not undertaken in a

vacuum, removed from other religious, philosophical, and social strivings. The state of

medical knowledge was one factor in the development of theory on marital intercourse.

The predominant institutional modifications of monogamous marriage in Roman society, namely, slave concubinage and easy divorce, affected the values which Christians would

stress in marriage. Contemporary Jewish thought and contemporary Stoic thought formed

other patterns limiting the impact of the Gospels. Gnostic speculation created a current to

which Christians reacted.

Within the intellectual and social context of the Roman Empire, the vital acts of

selection, discrimination, emphasis, and application of the Biblical texts were performed.

In this collaboration between the Christian community and the written word, under the

pressures generated by Roman life, the teaching on contraception took place.18

 

Stoicism influenced the Christian view by eliminating emotion as a legiti-

mate part of life.19 The rationale for intercourse then, almost by necessity,

 

   14 "Didache," The Apostolic Fathers, trans. and ed. J. B. Lightfoot (Grand Rapids: Baker

Book House, 1956), p. 124.

   15 Exodus 21:22-3 reads in the RSV, "When men strive together, and hurt a woman with

child, so that there is a miscarriage, and yet no harm follows, the one who hurt her shall be

fined, according as the woman's husband shall lay upon him; and he shall pay as the judges

determine. If any harm follows (replaced in the LXX by-'But if it be formed ... ') then

you shall give life for life."

   16 Raphael Loewe, The Position of Women in Judaism (London: S.P.C.K., 1966), pp.

36-7.

   17 Philo, De Josepho, 9.43 and De Abrahamo 137.

   18 Noonan, pp. 45-6. Yates attempts to show similar influences in the early 20th century

that helped change attitudes toward contraception.

   19 Noonan, pp. 46-8. This influence is directly tracable in extant writings of both the

Church fathers and certain Stoic writers. Seneca writes that "All love of another's wife is

shameful; so too, too much love of your own. A wise man ought to love his wife with

judgment, not affection. Let him control his impulses and not be borne headlong into

copulation. Nothing is fouler than to love a wife like an adulteress. Certainly those who say

45



46                                Christian Scholar's Review

 

became procreation rather than love or pleasure. At the same time the influence

of Gnosticism caused another reaction. Reacting to the licentiousness of some

Gnostics and the asceticism of others, the fathers took a middle ground. By

combining reaction and the overvaluation of virginity, intercourse became under-

stood as simply a procreative act.20

Preceding the fourth century there is no clear-cut condemnation of contra-

ception in any official manner, although there are less clear references.21 The

view that came to dominate in the Church was formed by Augustine in reaction

to the Manichees and as a result of incidents in his personal life.22 Along with

his theology, his view became for a while the teaching of the whole Church. No

official change in the attitude of the Church in any of its major branches took

place until a Lambeth conference of the Church of England in the early 1930s

declared contraception acceptable under certain limited conditions.23

 

THE OLD TESTAMENT

AND THE PROBLEMS OF CONTRACEPTION AND ABORTION

 

It is difficult to deal with the problems of abortion and contraception in the

Old Testament because of the nature of Old Testament culture. The children of

Israel considered children a blessing and sterility a curse:24

 

     Grandchildren are the crown of the aged, and the glory of sons is their fathers (Prov.

17:6).

Lo, sons are a heritage from the Lord, the fruit of the womb a reward. Like arrows in

the hand of a warrior are the sons of one's youth. Happy is the man who has his quiver full

of them! He shall not be put to shame when he speaks with his enemies in the gate (Psalm

127:3-5).

Your wife will be like a fruitful vine within your house; your children will be like olive

shoots around your table. Lo, thus shall the man be blessed who fears the Lord (Psalm

128:3-4).

... and Sarai said to Abram, ‘Behold now, the Lord has prevented me from bearing

children; ...’ (Genesis 16:2).

 

 

that they unite themselves to wives to produce children for the sake of the state and the

human race ought, at any rate, to imitate the beasts, and when their wife's belly swells not

destroy the offspring. Let them show themselves to their wives not as lovers, but as

husbands." (Seneca, Fragments, ed. Friedrich G. Haase (Leipzig, 1897), no. 84. See also

Jerome, Against Jovinian 1.49).

   20 Noonan, pp. 56-72.

   21 Ibid., pp. 73, 95.

   22 Ibid., ch. four.

   23 Bailey, p. 257.

   24 Might the fact that there is no word for bachelor in the Old Testament be an indication

(although not proof) of the value placed on marriage and its attendant relationships in Old

Testament times? Lucien LeGrand, The Biblical Doctrine of Virginity (New Y6rk: Sheed

and Ward, 1963), p. 29.

46



Cerling:  Abortion and Contraception                     47

 

 

     Jacob's anger was kindled against Rachel, and he said, ‘Am I in the place of God who

has withheld from you the fruit of the womb?’ (Genesis 30:2).

... and although he loved Hannah, he would give Hannah only one portion, because the

Lord had closed her womb (I Sam. 1:5).

 

Children are a means of perpetuating the family name and the covenant

people.25 With attitudes such as these being common in Israel, it is difficult to

imagine how contraception and abortion could become problems. They may

have been rejected without even being seriously considered.

 

      PURPOSE OF MARRIAGE

      Much of the discussion surrounding the problem of contraception deals with

the creative intent for marriage. Was marriage created by God for the purpose of

the procreation and education of children or was the purpose of marriage

companionship? Genesis 1:28 and 2:18 seem to conflict at this point. It has

generally been the teaching of the Catholic Church that the primary purpose for

marriage and intercourse is the procreation and education of children. Until the

early years of this century Protestantism generally concurred in this opinion.

Now almost all Protestants would say that companionship is more important

than procreation.26 Piper writes, "Although the Biblical writers are aware of the

intimate connection between sex and propagation sex is not regarded primarily

as a means for procreation of children. The reason that woman was created is

that God saw that it was not good for the man to be alone (Gen. 2:18)."27 He

then goes on to state that Genesis 1:28 is not to be taken as a command, but as a

blessing given to the original couple.28 Piper rightly states that "All that the

Bible has to say concerning sexual life is incomprehensible if we try to under-

stand it as based on the will to propogate."29 The intent of the Creator then

appears to have been companionship, sex being an important subordinate cre-

ative intent.30

 

    25 Piper, p. 33.

    26 Thielicke, pp. 204-5 states that procreation is a secondary reason for marriage. If the

primary purpose, companionship, will be destroyed by the exercise of the secondary

purpose, then the secondary purpose may be ignored.

    27 Piper, p. 30.

    28 Ibid., pp. 32-3.

    29 Ibid., p. 32.

    30 Charles Edward Cerling, Jr., "A Wife's Submission in Marriage, (Unpublished master's

dissertation, Trinity Evangelical Divinity School, 1968), pp. 11-13. See also James Patrick

Lyons, The Essential Structure of Marriage (Washington: Catholic University Press of

America, 1950), pp. 18-19. Erhardt Paul Weber, "A Christian Theology of Marriage,"

(Unpublished Th.D. dissertation, Chicago Lutheran Theological Seminary, 1961), pp. 35-8.

Ebbie C. Smith, "The One-flesh Concept of Marriage; A Biblical Study," (Unpublished

Th.D. dissertation, Southwestern Baptist Theological Seminary, 1961), pp. 15-39. Piper, p.

137.

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48                                Christian Scholar's Review

 

Genesis 1:28 does pose a problem. This verse, usually understood as a

command, seems to suggest that all couples should have three or more children.

(For two to multiply they have to become three.) But is this verse a command?

It is imperative in mood, but this mood is used for blessings along with the

indicative.31 There are eight other places in Genesis32 where the introductory

formula, "blessed ... and said . . . " is used with the imperative. Therefore it

would appear that Genesis 1:28 is a blessing rather than a command; but it

would also appear from this verse that the Creator intended that each couple

should produce children.33 The blessing suggests one of the major purposes of

marriage, although procreation is not the purpose of marriage. If it were, the

marriage of the sterile and aged would probably have been condemned.

 

     CONTRACEPTION

     Leviticus 15:18 may have a bearing on the question of contraception.

Waltke interprets the verse to mean that ejaculation without procreative intent is

acceptable.34 If this passage refers to coitus interruptus his interpretation is

sound. Although the author agrees with Waltke35 other interpretations are

possible. The passage may be referring to sperm that runs from or does not fully

enter the vagina and therefore soils either garments or skins. It may also refer to

a nocturnal emission while one is sleeping with his wife, since akhabh will bear

either the rendering "sleep" or "intercourse."

The single most misunderstood passage on the whole topic of contraception

is Genesis 38. What was the sin of Onan for which he was killed by God? The

traditional interpretation of the Church has been that Onan was condemned for

coitus interruptus. No modern commentator supports this view. One must go to

19th century works to find support for such a position.36  Onan's sin is variously

 

    31 W. J. Harrelson, "Blessings and Cursings," The Interpreter's Dictionary of the Bible, I,

(New York: Abingdon Press, 1962), 446.

    32 9:1; 14:19; 24:60; 28:1; 35:9; 48:3; 48:15; 1:22 (slightly different).

    33 See also Genesis 9:1, 7. Arguing from the meaning of Gen. 1:28 (although this is not

directly stated) Kenneth R. Kantzer, "The Origin of the Soul as Related to the Abortion

Question," Birth Control and the Christian, eds. Walter O. Spitzer and Carlyle L. Saylor

(Wheaton: Tyndale, 1969), 553, argues that abortion is wrong because it goes contrary to

the intent of the Creator as here revealed. If what he says is true, it is equally an argument

against birth control, which also frustrates the intent of the Creator for a short period of

time.

    34 Waltke, p. 19.

    35 Waltke errs in including vv. 16-7. The discussion should be limited to v. 18, since vv.

16-7 refer only to nocturnal emissions. The inclusion of vv. 16-7 clouds the issue under

discussion.

    36 C. F. Keil, and F. Delitzsch, Biblical Commentary on the Old Testament, I, trans.

James Martin (Grand Rapids: Wm. B. Eerdmans Pub. Co., n.d.), 340.

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Cerling:  Abortion and Contraception                                 49

 

explained as mockery of the responsibilities of levirate marriage,37 to a simple

statement that he was condemned not for contraception but for an act (unde-

fined) which God condemned.38 Even the article in the New Catholic Encyclo-

pedia states that Onan's sin is unclear.39 The only fact on which all commenta-

tors now agree is that Onan was not punished for practicing contraception per

se.

Except for the practice of coitus interruptus and anal intercourse most

moderns would assume that few, if any, other contraceptive means were

known.40 Noonan gives many examples of methods of contraception found in

the ancient world.41 In particular he refers to Egypt where the children of Israel

spent some 400 years. Although the means range from the exotic (a willow bark

potion mixed with the burned testicles of a castrated ass) to quite simple devices

(a swab of wool coated with honey inserted into the vagina), some must have

been effective in at least moderate degrees. Some of these means (particularly

potions) have been tested on rats in modern medical laboratories and found to

be effective in inducing temporary sterility. The effectiveness of the methods

used is also demonstrated by occasional complaints in official sources that the

poor are having more children than the wealthy and educated because the poor

are not using contraceptive means. (Sounds rather modern!) From all this one

can conclude that the Israelities knew of various means of contraception.

Whether they used them is a question that will be treated below.

There are no passages in the Old Testament that treat contraception explic-

itly. A few passages bear indirectly on the topic and may provide some under-

standing of how the problem was faced. Continence might appear to be a natural

form of contraception, but Exodus 21:10 shows that regular intercourse is a

duty of marriage even if one has more than one wife, which would suggest that

continence would be wrong.42 Furthermore, the prohibition of intercourse

during menstruation (Lev. 15:19-28; 20:18) would work as a reverse contra-

ception. Because one would not have intercourse for seven days after the onset

(possibly completion) of menstruation, by the time one could have intercourse

again pregnancy would be more likely to occur. Not only would one be closer to

the fertile period, but there would be a large accumulation of semen from the

period of abstinence. Castration, whether voluntary or involuntary, was grounds

 

   37 Waltke, p. 19.

   38 J. T. Noonan, Jr. "Authority, Usury, and Contraception," Cross Currents XVI (Winter,

1966), 57.

   39 J. D. Fearon, "Onanism," (New York, 1967), p. 696.

   40 Waltke, p. 9, errs in assuming no mechanical contraceptives.

   41 Noonan, Contraception .... ch. one.

   42 Waltke, p. 16.

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50                                Christian Scholar's Review

 

for excommunication from the religious community (Dt. 23:1), which would

eliminate a rather gross form of contraception.43

      Alongside of these negative indications are other more positive indications of

the Old Testament attitude toward contraception. If Leviticus 15:18 refers to

coitus interruptus44 then one form of contraception was practiced without the

express condemnation of scripture. In various places in the Old Testament sex

crimes of various sorts are condemned, but contraception is never listed as one

of those crimes.45

In summary one can say that contraception was either never an issue with

the children of Israel because of their high regard for children, or it was an

accepted practice not considered worth mentioning. On the basis of our knowl-

edge of the methods of contraception used in the ancient world one would be

inclined to conclude that Israelites not only knew of contraceptive means, but

considered them so normal that no mention is ever made of the topic. At the

same time one must add the proviso that with the Israelite attitude toward

children, people must have had very strong reasons for using them when they

did.

 

ABORTION

One faces the same problem in dealing with abortion that one faces in

dealing with contraception: no passages deal with the topic directly. The only

passage that is assumed by some to treat of abortion is Exodus 21:22-24.46

Arguing from the meaning of the word yeledh Keil states that the passage deals

with a child, and has nothing to do with an abortion.47 Other commentators

treat the passage as dealing only with a special instance of involuntary abortion

that was induced by a second party.48

Waltke argues from this passage (Ex. 21:22-24) in comparison with Leviti-

cus 24:18 that a fetus is not a person.49 Since the death penalty is demanded

 

    43 This passage should not force one to conclude that sterilization is wrong. (Waltke, p.

22.) There is a great deal of difference between sterilization and castration.

    44 Above p. 49.

    45 Lev. ch. 18; 20:18; 15:16-33; Ez. 18:6; Dr. 27:20-23.

    46 Viktor Aptowitzer, "Observations on the Criminal Law of the Jews," Jewish Quarterly

Review XV (1924), 65ff, shows how this passage is used in Jewish thought to support both

a "murder" theory of abortion and a rather lax approach. The differences appear to be

based on the version of scripture used. The MT supports the lax position; the LXX supports

the "murder" theory. This may have a bearing on the Church's position as it developed

through the use of the LXX.

    47 C. F. Keil, and F. Delitzsch, Biblical Commentary on the Old Testament, II, trans.

James Martin (Grand Rapids: Wm. B. Eerdmans Pub. Co., n.d.), 134-5.

    48 U. Cassuto, Genesis (Jerusalem: Magnes Press, 1960), pp. 275-6.

    49 Waltke, pp. 10-11.

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Cerling:  Abortion and Contraception                     51

 

for murder, and only a fine is paid if the fetus dies without injury to the mother,

the fetus is not considered human. He also states that the use of nephesh in the

second part of the passage shows that the mother is a person while the fetus is

not. But the fact that a fetal death is not punished by another fetal death also

shows that the fetus was highly regarded.50

Other passages may also have a positive, although indirect, bearing on the

topic. In Leviticus 20:11-21 all sexual crimes punishable by death are listed--no

mention is made of abortion. In Leviticus 18:21; 20:2 child-killing is condemned

in connection with the worship of Moloch. Abortion is not mentioned here

either, although it could be argued that it has no bearing here. Other passages

(Lev. 15:16-33; ch. 18; Dt. 27:20-3) dealing with sexual behavior make no

mention of abortion.

An Assyrian law states concerning the problem of abortion:51

 

(If a seignior) struck a(nother) seignior's (wife) and caused her to have (a miscarriage),

they shall treat (the wife of the seignior), who caused the (other) seignior's wife to (have a

miscarriage), as he treated her; he shall compensate for her fetus with a life. However if

that woman died, they shall put the seignior to death; he shall compensate for her fetus

with a life. But, when that woman's husband has no son, if someone struck her so that she

had a miscarriage, they shall put the striker to death; even if her fetus is a girl, he shall

compensate with a life.

 

Waltke argues from this law that the death penalty is required in Assyria for

inducing an abortion by striking a woman.52 That is true, if the woman also

dies, but the quotation may suggest that the death of the fetus only calls for the

death of another fetus unless the man has no heir.

Considering the general attitude of the Church through its history toward

the problem of abortion that it is equivalent to murder, the failure of the Old

Testament to mention it either explicitly or implicitly is significant. Again, it

may never have been a problem in a country that desired children as strongly as

the Israelites appear to have,53 but if others did it, which we know from

 

    50 Ibid., p. 12. J. W. Montgomery, "The Christian View of the Fetus," Birth Control and

the Christian, eds. Walter 0. Spitzer and Carlyle L. Saylor (Wheaton: Tyndale House Pub.,

1969), pp. 88-9 argues that Ex. 21:22-24 does not distinguish the life of the mother from

the life of the child in meting out punishment. The injury may be to either mother or child,

and if either is injured, punishment equivalent to the injury should follow. Waltke gives an