Litigating abortion rights on the continent is fraught with difficulty with restrictive legal regimes, political hurdles and hostile social attitudes which would forestall the implementation of any court decisions; the absence of indigenous jurisprudence and failures by judges and lawyers as well as the preference by stakeholders to rely on non-adversarial means to realize progress on what is a hot-button political and socio-cultural issue. This is indeed the reason for the absence of abortion litigation in the Litigating Reproductive Justice in Africa (LIRA) Programme focus countries. Excluding criminal prosecutions and undecided litigation that are a preserve of the state and which rarely if ever are based on human rights, there are only four decided constitutional or civil cases in the six LIRA Programme focus countries.