[8] Nikolaos Kostes, the first professor of obstetrics at Athens University, distinguished between a emvyro (fetus), a vrefos (infant), and a kyema (literally, 'that which is conceived').
Kostes stated the fetal body parts could be discerned around the sixth week of pregnancy, and referred to the first three months of fertilized ova as 'the egg'.
Therefore, if a woman was pregnant in the early months of gestation was not considered a fetus, any action taken to terminate a pregnancy could not be punishable by law.
In a 1905 Supreme Court case, a judge ruled that a necessary element of article 303 was that 'the mother gave birth to a dead or premature fetus'.
The judge specifically clarified that article 303 applied "even when the conception is recent and the fetus had not started giving signs of life yet".
[9] Contradictorily, article 106 of the penal code specified that 'a person who undertook an illegal act in order to urgently protect their own or someone else's life' should not be punished.
The women's movement organized protests and marches throughout Greece to bring attention and awareness to contraception and published informational material.
In 1980 the Minister of Health, Welfare and Social Insurance, Spiridon Doxiadis, established 10 family planning clinics within selected major urban hospitals.