by jimmykeogh30

Ireland’s euthanasia laws are some of the most strict in Europe

Here’s a look at the situation in other countries.

Image: Niall Carson/PA Wire

IT HAS NOW been more than a year since the death of Marie Fleming, but the debate sparked on euthanasia and the right to die has continued.

She lost a legal case at the Supreme Court in 2013 to secure a right to die. She wanted to ensure that her partner, Tom Curran, would not be prosecuted if he helped her to end her life.

The court ruled that there is no Constitutional right to die, or to be helped to do so.

However, that was wasn’t the end of her fight. Curran is now is drafting new legislation on new right-to-die laws.

And Marie’s case wasn’t an isolated one.

In October, Katie Tobin shared her story of being diagnosed with Multiple Sclerosis two years ago, and has now reached the stage where she must take 42 tablets a day.

She said that if she was an animal, she ‘would be put to sleep’.

“It’s something I have put a lot of thought into…I didn’t just decide I wanted to die,” she told TV3′s Ireland AM.

I know the progression my illness is going to take – I will end up taking up a hospital bed and taking treatment that will keep me comfortable.

The following month, the story emerged of Brittany Maynard. Although it took place in the United States it still struck a chord in Ireland.

She was diagnosed with terminal brain cancer in April, and told that at just 29, she had six months left to live.

“I will die upstairs in my bedroom with my husband, mother, stepfather and best friend by my side, and pass peacefully,” Brittany said.

Oregon, where Brittany lived, has a Death With Dignity Act that enables people to self-administer lethal medications.

Her death even provoked a response from the Vatican, with a senior official condemning her death as wicked.

French lawmakers unveiled proposals last month for a bill that would allow doctors to plunge terminally-ill patients into a deep sleep until they die, reviving the deeply divisive end-of-life debate.

The bill would also make “living wills” — drafted by people who do not want to be kept alive artificially if they are too ill to decide — legally binding on doctors rather than merely consultative as they are now.

This type of sedation can also be used on patients who are not able to make decisions, in certain circumstances.

However, vast variations exist across Europe in laws on euthanasia.

AFP has compiled this run-down of the situation in each country.

Legalised

In the Netherlands, active, direct euthanasia has been legal since April 2002. Requested administration of a drug in lethal doses is authorised if patients make the request while fully mentally lucid. They must also endure unbearable and endless suffering from a condition diagnosed as incurable by at least two doctors.

The Netherlands has also authorised euthanasia for children younger than 12 under strict conditions.

Belgium lifted restrictions on euthanasia in September 2002 for patients facing constant, unbearable and untreatable physical or psychic suffering; aged 18 or over; and who request termination of life in a voluntary, deliberated and repeated manner free from coercion.

Provisions for doctor-assisted death in cases that meet those criteria may also be stipulated in “living wills” written by healthy people before they fall ill, and which remain valid for five years.

In February 2014, Belgium became the first country to authorise children to request euthanasia if they suffer a terminal disease, and understand the consequences of the act.

In Luxembourg a text legalising euthanasia in certain terminal cases was approved in March 2009. It excludes minors.

Authorised or tolerated

Switzerland is one of the rare countries that allows assisted suicide by patients administering a lethal dose of medication themselves. Switzerland does not allow active, direct euthanasia by a third party, but tolerates the provision of substances to relieve suffering even if death is a possible side-effect.

Passive euthanasia, or the halting of medical procedures that maintain life, is also tolerated.

Dignitas Switzerland

The interior of a flat in the city centre of Zurich rented by the euthanasia organisation Dignitas, and where some of their patients spend their last moments.

Source: Keystone Switzerland/Press Association Images

In France, a 2005 law acknowledges a “right to die” in connection with procedures to ease suffering.

A doctor can prescribe pain killers even if their use under certain conditions may result in death, provided the patient is in an advanced stage of an incurable disease.

Sweden authorised passive euthanasia in 2010.

Britain has allowed medical personnel to halt life-preserving treatment in certain cases since 2002. Prosecution of those who have helped a close relative die after clearly expressing the desire to end their lives has receded since 2010.

In Austria and Germany, passive euthanasia is permitted if the patient has requested it.

Since 1992, Denmark has allowed patients to file previously written refusal of excessive treatment in dire situations, with the document held in a centralised register.

In Norway, passive euthanasia is permitted if requested by the patient, or by a relative if the patient is unconscious.

In Hungry, Spain, and the Czech Republic, people with incurable diseases can refuse treatment.

In Portugal, active and passive euthanasia is not legal, but an ethical council has approved the halting of treatment in certain cases.

Prohibited

In Ireland, Italy, Romania, Greece, Bosnia, Serbia, Croatia, and Poland, euthanasia is forbidden, and considered homicide. Punishment can range from 14 and 15 years in prison in Ireland and Italy respectively, to relatively light sentences in Croatia.

– © AFP, 2014, with reporting by Nicky Ryan and TheJournal.ie

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