Euthanasia: where does the rest of the world stand?

The debate about assisted dying is dividing Victoria. How do different countries treat the issue?

People proteting in Madrid

People proteting in Madrid demanding freedom for dignified death in 2015. Source: LightRocket

In Victoria, legislation that allows euthanasia - the deliberate killing of a patient suffering from an incurable disease, at their request - is currently being drafted following 66 recommendations from a ministerial advisory panel.

It could be finalised within months and voted on by the end of the year. However, there has been opposition within the state government with Victoria's Deputy Premier James Merlino saying he will oppose the government bill.

Voluntary euthanasia and assisted suicide are illegal in .

On Wednesday night, a push to allow territories the right to legalise euthanasia was killed off in the Senate, with a majority of the chamber voting against the proposal

The only end-of-life laws that exist are made up of Advance Medical Directive and Power of Attorney laws.

These laws do not allow a person to ask for assistance to die and operate differently in each state. 

In South Australia in November last year, a conscience vote on proposed euthanasia legislation was narrowly defeated.

In NSW, a voluntary assisted dying bill will be presented in parliament later this year. Voluntary assisted dying is when a terminally ill person requests and receives assistance to end their lives voluntarily.

The Northern Territory was the first jurisdiction in the world to legalise physician-assisted euthanasia, passing the Rights of the Terminally Ill Act in 1995.

Terminally ill cancer sufferer Bob Dent was the first person to end his life under this act in 1996.

The Euthanasia Laws Act 1997 later removed the power of the Nothern Territory parliament to legalise Euthanasia.

The legal status of euthanasia around the world

Every person has a right to life, which is outlined under Article 6 (1) of the :

"Every human being has the inherent right to life. This right shall be protected by law. No one shall be arbitrarily deprived of his life."

The competing interest to this right is a person's right to die with dignity.

  • Belgium 
It has been legal since 2002.

  • Luxembourg 
It has been legal since 2008.

  • The Netherlands 
It has been legal since 2002.

  • New Zealand
Euthanasia is illegal in New Zealand despite two failed attempts to decriminalise it – in 1995 and 2003.

  • The US
Euthanasia is illegal in most US states, but assisted suicide is legal in Washington DC, California, Colorado, Oregon, Vermont, and Washington.

  • Norway
Euthanasia is illegal in Norway. But a carer may receive a lesser sentence if they help to end the life of a terminally ill person.

  • Ireland
Euthanasia and assisted suicide are illegal in Ireland. A 2013 Supreme Court ruling rejected a terminally ill woman's request to die with the assistance of her partner.

  • Switzerland
Assisted suicide is legal in Switzerland but active euthanasia is illegal under Article 114 of the Swiss Penal Code.

  • UK
Both euthanasia and assisted suicide are illegal under English law. The maximum penalty is life imprisonment.

  • Canada
The High Court  in 2015 and it became legal in 2016.

  • China
Articles 232 and 233 of the Criminal Law of the People's Republic of China forbids euthanasia.

There was an attempt to legalise it in 1994 by legislators from the National People's Congress but it was not passed. 

  • France
Euthanasia is illegal in France, however in 2016, in what has been seen as a compromise, France's parliament passed a law that permits doctors to put terminally-ill patients to sleep until they die.  

  • Germany
In 2015, Germany passed a law that enables physician-assisted suicide. However, euthanasia is illegal.

  • India
Euthanasia is still illegal in India. However in 2016, the government asked the public for its opinion on a draft Terminally Ill Patients (Protection of Patients and Medical Practitioners) Bill that would legalise passive euthanasia if it were passed. Passive euthanasia means medical professionals do not intervene to keep a patient alive.

  • Israel
Israel's Penal Law forbids euthanasia as does Jewish law. However in 2014, the Tel Aviv district court authorised the avoidance of treatment of a patient suffering from amyotrophic lateral sclerosis and could only communicate through the movement of his eyes. 

  • Italy
Euthanasia is illegal in Italy, and became the centre of debate after a paralysed DJ Fabo chose assisted dying in a Swiss clinic in February 2017.

  • Russia
Russia's health care law 'On Health Care of Russian Citiziens', passed in 1993, forbids euthanasia.

  • Spain
Spain forbids euthanasia, and it's an issue that became the centre of debate when in April media reported that Spanish man, José Antonio Arrabal, who suffered from amyotrophic lateral sclerosis, took his own life after asking the government to decriminalise euthanasia.

5 min read
Published 26 July 2017 at 4:12pm
By SBS World News
Source: SBS