The British Offences Against the Person Act 1861, which made "unlawful procurement of a miscarriage" a crime, remained in force after Irish independence in 1922. The 1983 Eighth Amendment of the Constitution, which declares "the right to life of the unborn ... equal [to the] right to life of the mother", was instigated by the Pro-Life Amendment Campaign for fear that the 1861 prohibition might be weakened by liberal legislators or activist judges. The 1992 "X case" (Attorney General v. X) ruled that abortion is permitted where pregnancy threatens a woman's life, including by risk of suicide. No regulatory framework within the limited scope of the X case judgement was passed until the Protection of Life During Pregnancy Act 2013, impelled by the 2010 A, B, and C v Ireland case in the European Court of Human Rights and the 2012 death of Savita Halappanavar after miscarriage. The 2013 act repealed the 1861 act, and makes "destruction of unborn human life" a crime. In the three years 2014–2016, a total of 77 legal abortions were performed under the 2013 act.