ABSTRACT
Euthanasia, death and dying give rise to similar dilemmas and problems throughout the world. Indeed, in the past 50 years, several Western countries have wrestled with the dilemmas associated with the rapid advances in technology. We have already seen how English law has tried to deal with the problem. In comparative terms, there appears to be only one State, the Northern Territory of Australia, which once passed a statute, in the autumn of 1996, allowing a doctor to assist a terminally ill patient to die, although this law contained several safeguards and prior consultations. This statute has now been repealed, and was law for only six months. However, in the Netherlands, Switzerland and Germany, it has been claimed that both voluntary euthanasia and assisted suicide are openly practised, even though neither practice is legal in these countries (see Vickers (1997)). As we have already mentioned in Part I, there is a voluminous amount of literature, academic, medico-legal, and informational on the subject of euthanasia generally. Indeed, there is major research continuing in Scotland, which produced the first ever book on ‘self-deliverance’. In Europe, North America and Australia, changes in policy have attracted a great deal of global interest. Several American jurisdictions have, on occasion, also challenged the constitutionality of laws against assisted suicide. However, it is to the Netherlands that we first turn as, over the years, it has become the most cited jurisdiction for euthanasia whenever any comparisons are made with noncommon law countries.
