In contrast, 34 countries as of 2021 have definitions of marriage in their constitutions that prevent marriage between couples of the same sex, most enacted in recent decades as a preventative measure.
However, the ECHR stated in Schalk and Kopf v Austria that this provision was intended to limit marriage to heterosexual relationships, as it used the term "men and women" instead of "everyone".
In 2001, Rowe went to a to have her for the two children terminated.