Bishop Patrick Dunn says abortion can only be a truly 'free' choice if the woman knows there's support that enables her to choose to keep the child.

The state would fail its responsibility to care for all human life if it were to make abortion solely a matter between woman and doctor, according to the New Zealand Catholic Bishop's Conference (NZCBC).

The group expressed its concerns in a submission to the Law Commission about Justice Minister Andrew Little's proposal to make abortion a health issue rather than a criminal one - a move abortion law-change advocates called "not all that surprising", as they questioned the NZCBC's points raised.

Little wrote to the commission in February to ask advice on what changes could be made to the country's legal framework to achieve that.

The NZCBC said in its letter the legal framework the commission had been tasked to provide "would effectively amount to a significant policy change". The submission also calls for a review of the "social support structures, familial, financial, emotional and social, that our society offers to women who are pregnant".

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"The NZCBC and its centre of bioethics, The Nathaniel Centre, are concerned that such a move would limit or remove the rights of the unborn child that the current law acknowledges," the group wrote. "They say that abortion is both a health and a justice issue and it should continue to be treated by the law as such."

NZCBC president, Bishop Patrick Dunn, said: "The changes we would advocate for are those which will ensure continued consideration of the rights of the unborn child and promote the well-being of women, including better processes to ensure adequate informed consent, especially independent counselling.

"A decision for an abortion can only be described as a truly 'free' choice if the woman knows there is tangible support that enables her to choose to keep the child."

JOEL MAXWELL/STUFF Terry Bellamak, national president of the Abortion Law Reform Association of New Zealand.

﻿Terry Bellamak, president of the Abortion Law Reform Association New Zealand, which is campaigning for changes to the law, said all in-in-all, the NZCBC's submission revealed a "profound mistrust of pregnant women" and that it was written from a "very Catholic" viewpoint.

"The point is that people who think that abortion is immoral have the option never to have one. People who decide that that is the moral choice for them should be able to access abortion care ... no-one else should be able to control that decision for them."

Bellamak took issue with other parts of the submission.

"They seem to be suggesting - without providing any evidence - that abortion counselling that people currently receive is not independent. That does not comport with what I understand or what I have heard from people who have accessed abortion in New Zealand," she said.

"Universally, almost every woman has said the counselling is certainly independent and was very much in keeping with giving them enough information to give informed consent.

"It also kind of makes the suggestion that clinicians or counsellers were not concerned with uncovering any coercion around the decision to access abortion care, again without any evidence showing that. It would certainly surprise the Ob-Gyns that I know who provide abortion care and it doesn't really agree again with what I know of abortion care."

During the election campaign, Labour leader Jacinda Ardern was vocal about her desire to remove abortion from the Crimes Act and to make it a health issue.

ROBERT KITCHIN/STUFF Justice Minister Andrew Little wrote to the Law Commission in February to get advice about making abortion a health issue rather than a criminal one.

In February, Little said he expected to be able to report back to Parliament by the end of the year but any new legislation would be a conscience vote.

"For a start, just looking at the language in the legislation, and looking at the steps the legislation requires women to go through in order to get an abortion. And then there is this aspect that effectively decriminalises it.

"The whole lot needs to be looked at," he said.

Now prime minister, Ardern said her position hadn't changed and the laws needed to be updated.

The abortion laws are 40 years old but the previous government steered away from making changes.

Submissions to the Law Commission closed last Friday, and the commission is expected to advice Little in October.