Countries where euthanasia is legal
Assisted dying is allowed in a growing number of countries - but not the UK
Euthanasia is illegal under English law, but the number of countries where it is permitted is growing.
Those in favour say that in a civilised society, people should be able to choose when they are ready to die and should be helped if they are unable to end their lives on their own.
But some critics take a moral stance against euthanasia and assisted suicide, saying life is given by God and only God can take it, says the BBC. Others think that laws allowing euthanasia could be abused and people who didn’t want to die could be killed.
The terminology around euthanasia is sometimes inconsistently applied, but there is a difference between euthanasia, assisted suicide and assisted dying, says The Guardian.
Euthanasia refers to an instance where active steps are taken to end someone’s life, but the fatal act is carried out by someone else, such as a doctor.
Assisted suicide is when someone takes their own life but is assisted by somebody else. Rather than a doctor carrying out the fatal act, they themselves do so.
Assisted dying can refer to either euthanasia or assisted suicide.
Under the Suicide Act 1961, both euthanasia and assisted suicide are criminal offences in the UK. Euthanasia can result in a murder charge, and assisted suicide by aiding or even counselling somebody in relation to taking their own life is punishable by 14 years’ imprisonment.
But there are countries where euthanasia is legal, usually under strict conditions.
Probably the first country that comes to mind in relation to assisted dying, Switzerland allows physician-assisted suicide without a minimum age requirement, diagnosis or symptom state.
However, assisted suicide is deemed illegal if the motivations are “selfish” - for example, if someone assisting the death stands to inherit earlier, or if they don’t want the burden of caring for a sick person.
Euthanasia is not legal in the country.
In 2018, 221 people travelled to the Swiss clinic Dignitas for assisted suicide. Of these, 87 were from Germany, 31 from France and 24 from the UK.
About 1.5% of Swiss deaths are the result of assisted suicide.
Euthanasia and assisted suicide are legal in the Netherlands in cases where someone is experiencing unbearable suffering and there is no chance of it improving. There is no requirement to be terminally ill, and no mandatory waiting period.
Children as young as 12 can request assisted dying, but parental consent is needed for those under 16.
There are various checks that have to be undertaken before assisted dying can be approved. Doctors who are considering allowing assisted dying must consult with at least one other, independent doctor to confirm that the patient meets the necessary criteria.
Belgium allows euthanasia and assisted suicide for those with unbearable suffering and no prospect of improvement. If a patient is not terminally ill, there is a one-month waiting period before euthanasia can be performed.
Belgium has no age restriction for children, but they must have a terminal illness to meet the criteria for approval.
Assisted suicide and euthanasia are both legal in Luxembourg for adults. Patients must have an incurable condition with constant, intolerable suffering and no prospect of improvement.
Canada allows euthanasia and assisted suicide for adults suffering from “grievous and irremediable conditions” whose death is “reasonably foreseeable”.
In Quebec, only euthanasia is allowed.
Terminal patients can request voluntary euthanasia in Colombia, and the first such death happened in 2015. An independent committee must approve the request for assisted dying.
The Australian state of Victoria passed voluntary euthanasia laws in November 2017 after 20 years and 50 failed attempts. The Australian Senate had previously repealed the law in 1997 owing to a public backlash against the 1995 law that allowed it.
To qualify for legal approval, you have to be an adult with decision-making capacity, you must be a resident of Victoria, and have intolerable suffering due to an illness that gives you a life expectancy of less than six months, or 12 months if suffering from a neurodegenerative illness.
And a doctor cannot bring up the idea of assisted dying, the patient must raise it first.
You have to make three requests to the scheme, including one in writing. You must then be assessed by two experienced doctors, one of whom is a specialist, to determine your eligibility, says The Guardian.
If eligible, you will be prescribed drugs which you must keep in a “locked box” until a time of your choosing. If you can’t administer the fatal drugs yourself, a doctor can administer a lethal injection.
Several states now offer legal assisted dying. Oregon, Washington, Vermont, California, Colorado, Washington DC, Hawaii, New Jersey, Maine and Montana all have laws or court rulings allowing doctor-assisted suicide for terminally ill patients.
Doctors can write patients a prescription for the fatal drugs, but a healthcare professional must be present when they are administered.
All of the states require a 15-day waiting period between two oral requests and a two-day waiting period between a final written request and the fulfilling of the prescription.
Palliative sedation, in which someone can ask to be deeply sedated until they die, is permitted in France, but assisted dying is not.
A bill legalising voluntary euthanasia passed its second vote in parliament in June by 70 votes to 50, says the NZ Herald.
However, a third and final reading is still required before the bill is passed into law, and it is far from guaranteed that it will succeed.
For now, both euthanasia and assisted suicide remain illegal.