In October 2016, 32-year old Valentina Miluzzo died of sepsis after a doctor at Cannizzaro obstetrics and gynaecology hospital in Catania on the east coast of Sicily refused to perform a termination following complications in her twin pregnancy.
Valentina's family and lawyer stated that the doctor refused to intervene on ethical grounds as the hearts of the foetuses were still beating. This story is very similar to Savita Halappanavar's. With a significant difference though: in Italy abortion has been legal for almost 40 years.
More recently, when the plans to hand over the new National Maternity Hospital to the Sisters of Charity were announced, I was reminded once again of the similarities between the two countries and the danger of a public hospital being in the hands of a religious order, something that is quite common in Italy.
Despite reassurances from the Government that the religious order would not wield influence over medical practices, the Irish general public has remained sceptical – and rightly so.
The right to abortion is often denied by the practical impossibility of finding a facility that would provide one
Based on the experience of my own country, I know for a fact this is practically impossible. As a young woman, I knocked at the doors of a public – yet religious – hospital looking for emergency contraception, only to be told they were not allowed to give it to me because it was a Catholic institution.
Church and state are separate in Italy, at least in theory. We have no mention of Catholic religion in our constitution; our members of Parliament do not recite a prayer before starting a session; our public schools are secular and the optional weekly class of religious education is controversial.
However, the presence of the Vatican on our soil and its constant interference in Italian politics, as well as strong links between the church and the political establishment, has meant that theory and practice have often diverged.
In the case of abortion, law 194 of 1978 decriminalised it, allowing for free, safe and legal abortion within the first 90 days of pregnancy, and after that time limit in cases of serious malformations.
The law, however, contains a clause defending the rights of those doctors who do not feel comfortable performing terminations due to ethical reasons.
The percentage of conscientious objectors remained at about 45 per cent for the first few decades, but in recent times – with a resurgence of religion globally – it has skyrocketed to an average of 70 per cent with peaks of 90 per cent in some regions.
If, in theory, women are entitled to an abortion, their right is often denied by the practical impossibility of finding a doctor and a facility that would provide one. A woman from Padua has reported that she had to visit 23 different hospitals, in three different regions, before she was able to terminate her pregnancy.
Women have the option of travelling to other regions where there are more non-objecting doctors, or having to resort to private clinics. The most worrying trend, however, is the increase in clandestine abortions.
The minority of doctors who do perform abortions are so overloaded with the number of surgeries that sometimes they cannot keep up.
In the region of Molise, which has the highest percentage of conscientious objectors (94 per cent), there is only one doctor willing to perform abortions, carrying out an average of 400 surgeries a year.
He, like many others in his situation, knows he cannot miss a day’s work and worries about where local women will turn to once he retires.
In April 2016, the Council of Europe found that the situation in Italy violated both the women's right to protection of health and the doctors' right to dignity at work.
The problem with law 194 is closely linked to the functioning of the health system and the ownership of Italian public hospitals. Some are directly owned by the Vatican, others by religious orders – a legacy of another era.
Irish campaigners should demand a law that gives priority to the rights of women over those of doctors
Even in hospitals that are owned solely by the state, doctors often need to conform to a religious ethos brought by head physicians who came from religious hospitals or have been trained in religious universities.
In most cases, it is not the conscience of the individual doctor that is at stake, but rather their career.
Such is the stigma still attached to abortion in the medical sector, that it is very difficult for non-objecting gynaecologists to achieve high positions within their departments.
The issue became a hot topic last February when the region of Lazio advertised a vacancy for two non-objecting gynaecologists for a Roman hospital, to make sure that the right of women enshrined in law 194 was implemented.
The Catholic Bishops’ Conference complained that this procedure would go against that same law as it would discriminate against conscientious objectors.
The minister for health supported the position of the church, generating a heated public debate, which once again raised the issue of the need for effective separation of church and state when it comes to health, in particular reproductive health.
The same minister for health has repeatedly claimed that the number of abortions is decreasing in Italy. While this was certainly the case after the law was passed, there are genuine reasons to believe that current official data are missing a large part of the picture: clandestine abortions carried out at great risk to women, the very same unsafe practices that the passing of the law in the 1970s wanted to eliminate.
This should certainly be a cautionary tale for Ireland. With the deliberations of the Citizens' Assembly and a referendum which I believe will be very difficult to avoid, campaigners should look at Italy, learn from its mistakes and demand a law that gives priority to the rights of women over those of doctors.
Abortion, however, is only one issue that can generate conflict between the medical profession and the church, between science and religion. That is why, in 2017, we cannot allow a public hospital to be handed over to a religious order.
Laura Fano Morrissey is a writer and social anthropologist based in Dublin. She has been a long-time activist for women's rights in Italy and internationally.