Following the enactment of the 1979 Family Planning Act, conservative groups sought to reassert Ireland’s traditional morality by demanding an amendment to the Irish Constitution guaranteeing the right to life of the ‘unborn’. The Supreme Court had cited similar arguments to Roe v. Wade in the McGee case, and it was alleged that similar arguments might result abortion being legalised in Ireland. The amendment was passed in September 1983. Following the 1967 British Abortion Act, a growing number of Irish women were travelling to Britain for abortions and this abortion trail grew in the 1980s and 1990s, despite restrictions on abortion referrals. In 1991 the Supreme Court ruled in the X case that abortion was legal in order to save a woman’s life. Three referenda held in 1992 affirmed the right to information about abortion and the right to travel for an abortion and rejected a proposal to reverse the Supreme Court judgement. This referendum was again rejected in 2002. The Pro-Life Amendment hindered the treatment of pregnant women and was a factor in the death of Savita Hallapanuvar in 2012.