The Law French phrase en ventre sa mere ("in its mother's womb") refers to a fetus in utero and is commonly used in Legal English.
An unborn fetus, which is thus still "en ventre sa mere", may be accepted to be a beneficiary for some purposes if it is subsequently born alive.
In the Australian case Watt v. Rama [1972] VR 353 it was deemed that a fetus is a person entitled, once born, to compensation as a plaintiff for injury caused while en ventre sa mère.
In Amadio v. Levin, 509 Pa. 199 (1985), the Supreme Court of Pennsylvania held that "it makes no difference in liability under the wrongful death and survival statutes whether the child dies of the injuries just prior to or just after birth."
In Farley v. Sartin Trucking, 195 W.Va. 671, the Supreme Court of Appeals of West Virginia did away with a requirement that a tortiously killed fetus be viable outside the womb at the time the tort was committed.