chapter  141
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International Comparisons

WithBasant K. Puri

This chapter briefly summarizes mental health legislation in a variety of English-speaking countries. It is based on the second edition of Mental Health Law: A Practical Guide.1

In the United Kingdom, there are three separate systems of legislation, for England and Wales, Scotland, and Northern Ireland, and therefore three different Mental Health Acts. The Republic of Ireland (Eire) also has separate legislation.