Annotation: There is no unified position as regards the legal status of the
embryo in Europe. Most International laws discard the possibility
of recognising an absolute right to life to an embryo or foetus.
The European Court of Human Rights had several occasions
to consider, and express itself on this question, but has always
avoided giving a clear opinion — leaving open the question of
whether Art. 2 ECHR also covers life before birth. In the recent
Parillo case it has been noted that it raises sensitive moral and
ethical issues with a wide margin of appreciation for the States.
Although there is no European consensus on the subject, it seems
that in the 21st century, the human embryo begins to enjoy a
gradual protection and in some situations the law acknowledges
some rights associated with it.