Zut Alors! There have been few pregnant pauses in the stream of invective surrounding the unsettlingly swift return to work this week of the French Justice Minister Rachida Dati just five days after giving birth to a baby daughter, and by Caesarean section to boot.

In returning to work so soon, is Dati sending out a worrying message to other working mothers? Not everyone thinks so. Self-employed Tessa Hartmann, a mother of four who runs her own marketing agency near Glasgow, for one.

"I think Rachida Dati is fantastic and should be congratulated," she says. "If she weren't physically able to go back to work she wouldn't do it. If you're in the right place emotionally and physically, why not? Who knows how she has prepared herself? I think we're being very judgmental about her. There's no reason for women not to do what they want."

Hartmann herself took no maternity leave and was back at her laptop within days of having her fourth child by Caesarean section two years ago. Hartmann, who has a full-time nanny, employed a yoga teacher and life coach when she was three months pregnant with Zachary, her youngest child, because she wanted to prepare herself for the fatigue and exhaustion that would follow his birth.

"I'm a workaholic, but Valerie taught me how to breathe and relax all the way through. Breathing properly is totally rejuvenating and energising. She also gave me the psychological mechanics to help me avoid negative words such as "fat" and "thin" and learn a new vocabulary about myself.

"I wouldn't be surprised if Rachida Dati was doing something similar. She's obviously prepared her body for this place and she is to be congratulated rather than condemned for that. People have to remember that for some of us, work is not a chore.

"If you lie down to fatigue and lethargy it just gets worse. If you push yourself and put on a bit of make-up, you instantly feel better."

On the other hand, Rachel Davis, 42, who plays viola with the Orchestra of Scottish Opera, was happy - and lucky enough - to take advantage of her employer's "fantastic" maternity scheme, which gives staff 15 weeks on full pay and 15 weeks on half pay. This enabled her to take off eight weeks before and seven months after the birth of her first son, Jamie, now four. With her second son, Kester, one year old, she took six weeks before and seven months after the birth. "Although it cost us a lot of money and I couldn't afford to take the extra three months without pay, I was very lucky to be able to do what I did," she said. "I was very tired in late pregnancy because my job is very physically demanding."

Having uninterrupted time with her babies in the "intense" early weeks was very important, she believes. "Your brain does go a bit mushy, but for good reason," she says. "You come to realise that those first months are not about you, they are about the needs of your baby. You're tuning into that, learning to go with the flow of their needs."

As a result, she feels a very strong bond with both her sons, and was happy to return to work because it felt like the right time to do so. She said: "I have sympathy for Rachida Dati if she feels she had to go back to work early. She hasn't had the time to bond with her baby."

Brenda Phipps, chief executive of the National Childbirth Trust, says situations like Dati's put pressure on women across the board. "In professional life there can be a culture of denial, where it's almost easier to deny we've become a mother than it is to accept we are one. Many women feel themselves caught in that cleft stick where they feel they can't do both. Just as society appears to value us more as workers than as parents, many women feel they get more status from their career than from motherhood.

"The last thing women want is the expectation to be set up that what Rachida Dati did is what should be done."

But a woman's body takes nine months to adjust to giving birth, and it's a major physical task that includes growing the uterus and raising blood volume. It takes another nine months for the body to return from that state.

"Women who don't give themselves sufficient time report feeling bone tired' and find it difficult to get their head around being a mother," says Phipps. "When there's a Caesarean wound involved they can have all sorts of issues around wondering if their stitches are going to re-open, and run the risk of infection."

British women have the right to 52 weeks' maternity leave, which must begin within 11 weeks before the due date, and two of which must be taken immediately after the birth. Nine months, or 39 weeks, are paid at 90% of salary for six weeks followed by statutory maternity pay of £117.18 per week for 33 weeks, though many employer schemes enhance that by paying some of the first weeks at full pay. The remaining three months are unpaid.

Unsurprisingly, most British women choose to defer starting maternity leave until as close to the birth as possible in order to cram in more fully-paid time off with baby before returning to work when statutory pay runs out.

This, says Phipps, is generous - but not generous enough. "Britain should be more like Norway and allow women to take a year off properly paid," she says. "Leaving it late means you use up physical and emotional energy that should be focused on you and your child.

"Motherhood means you enter a timeless world where you are not meeting work deadlines or objectives. You're changing your identity. Women who don't give themselves time to adjust tell us they don't feel in control of the situation when the baby is there."

Mothers in France would seem to agree with this position. "She seems to be saying she values her professional life over parenthood," says Odile Dufour, a teacher from Marseille who has two young children. Economist Sandra Gonzales, a mother of two who lives in Lyon and is currently on maternity leave, said: "People might now look down at women who take their legal, longer maternity leave." Gonzales adds, though, that because of Dati's ministerial responsibilities, her decision is "understandable". Certainly, Mlle Dati seems to feel pressure to return to public life - a situation which highlights the uneasy work/life balance still experienced by many modern working mothers."

In the United States, women have the right to 12 weeks' maternity leave - but without pay. As a result, more than one-quarter took no leave before giving birth for the first time between 2001 and 2003, according to the US census. This is not beneficial to the mother's or the baby's health, says Sylvia Guendelman, professor of maternal and child health at UC Berkeley's School of Public Health in California. She led two new studies to look at whether taking maternity leave could affect health outcomes.

"The aim is to decrease the rate of C-sections which are not only very costly but also lead to extended hospital stays and increased risks of complications from surgery and longer recovery time for the mother," she told ScienceDaily this week.

One study found that women who started their leave in the last month of pregnancy were less likely to have Caesarean sections, while the other study found that the longer new mothers delayed their return to work, the more likely they were to establish breastfeeding.

The US was found to fall far behind most industrialised countries in its support for job-protected paid maternity leave. Analysis of 17 European countries has linked failure to take leave with low birth weight and infant mortality. Paid leave, but not unpaid leave, significantly decreased low birth weight rates.

Crucially for Rachida Dati and others like her, Guendelman said: "The findings suggest that if a woman postpones her return to work she'll increase her chances of breastfeeding success. Also, women who are in jobs where they have more authority may feel more empowered with how they use their time."

Whether Mlle Dati will find she soon has more time with her daughter than she anticipated remains to be seen.

The Best and Worst of Maternity Leave Around The World

United Kingdom 52 weeks, 39 of which are paid (six weeks at 90% of salary, then £117 weekly for 33 weeks).

France 16 weeks fully paid (six to be taken before birth, 10 after) for first child, rising to 26 weeks for third child.

Italy 22 weeks at 80%, two weeks to be taken before the birth.

Germany 14 weeks at 100%, six to be taken before birth, 12-14 months at 67% of salary.

Ireland 26 weeks paid plus 16 weeks unpaid. Two weeks to be taken before the due date and at least four weeks after. No paid leave for fathers.

Israel 14 weeks at 100% of salary.

The Netherlands 16 weeks at 100% and then 13 weeks unpaid, although there are plans to extend this to 26 weeks this year.

Portugal 120 days at 100% or 150 days at 80%

Bulgaria 24 months paid leave at 90% of salary plus 12 months unpaid leave

Estonia 18 months paid leave at 100% of salary.

Switzerland 16 weeks at 100%, eight weeks of which is mandatory.

Norway 54 weeks paid leave at 80% of the mother's salary, to be shared with the father. Mother must take at least three weeks immediately after the birth.

Sweden 16 months paid leave at 80% of salary, to be shared with the father of the child (he gets 60 dedicated days).

Denmark 52 weeks paid, 18 to be taken by mother, at least two weeks by the father.

Canada 50 weeks paid leave, to be shared with father.

Worst

(with no paid maternity leave): Australia, United States, Liberia, Swaziland, Papua New Guinea.

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