Euthanasia: where does the rest of the world stand?

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

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

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 all states and territories of Australia.

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 before it reached the committee stage.

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.

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The history and future of euthanasia
The history and future of 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 International Covenant on Civil and Political Rights:

"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 struck down a prohibition on assisted dying 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.

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