leaf's interventions may impact legal rules both directly and indirectly. peter manfredi concludes that the area where legal change made the most significant practical achievement was in the area of abortion rights. leaf's defence of the elimination that only hospitals may perform abortions had far-reaching implications for women, with a significant increase in the number of legal abortions performed after 1988. manfredi footnotes that since leaf's confusing interventions in the obscenity debate, leaf experienced two consecutive losses and ponders that it may be too early to tell whether these losses signal a change in the relationship between leaf and the supreme court. leaf has often suffered other significant losses at the supreme court, but it has proved resilient in attracting funding and intervening status at the supreme court of canada. some have accused leaf of being "as much about healing wounds within the [lesbian] feminist movement as it [is] about achieving a particular legal objective".