Where is euthanasia legal?
Euthanasia has long prompted a debate over whether it should or shouldn't be legal.
But this depends on the country you're living in, with one Victoria Secret model in Canada even documenting her grandmother's decision to be euthanised after being diagnosed with terminal cancer, sparking a mixed reaction.
In a 2021 YouGov survey on public views of assisted dying in Britain, 73% of the British public supported some form of doctor-assisted death for those with terminal illnesses, while 50% supported similar measures for those suffering from a painful but not terminal illness.
So, here's a look at what exactly euthanasia is, and where it is and isn't allowed.
What is euthanasia?
'Euthanasia' is the act of deliberately ending a person's life to relieve suffering, according to the NHS. In countries where this is permitted, a doctor may deliberately give a patient with a terminal illness a drug they don't otherwise need with the aim of ending their life.
It is worth bearing in mind that not everyone agrees on the terminology for the process, the British Medical Journal (BMJ) points out.
For example, it outlines:
Assisted dying—Proponents of the Assisted Dying Bill 2015 in England and Wales argue that this term best describes prescribing life-ending drugs for terminally ill, mentally competent adults to administer themselves after meeting strict legal safeguards.
Assisted suicide—This term is often intended to describe giving assistance to die to people with long-term progressive conditions and other people who are not dying, in addition to patients with a terminal illness. The drugs are self-administered.
Voluntary euthanasia—This term describes a doctor directly administering life-ending drugs to a patient who has given consent.
Euthanasia wouldn't be voluntary if a person was unable to give their consent and another person makes the decision their behalf, perhaps because the ill person previously expressed this wish.
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Where is euthanasia legal?
Voluntary euthanasia is permitted in Belgium, Luxembourg, and the Netherlands.
In 2016, Canada legalised both voluntary euthanasia and assisted dying for people whose death is "reasonably foreseeable", in what it calls "medical assistance in dying", the BMA states.
Assisted dying, as defined by the above bullet-pointed definition, is legal and regulated in the US states of California, Colorado, Hawaii, Montana, Oregon, Vermont, and Washington, and in Washington, DC.
In 2017, a similar legislation was passed in Victoria in Australia.
Assisted suicide, as defined by the above definition, is permitted in Switzerland.
Is euthanasia legal in the UK?
In a nutshell, there answer is no.
As outlined by the British Medical Association (BMA), in England and Wales:
Euthanasia is illegal and could be prosecuted as murder or manslaughter
‘Assisting or encouraging’ another person’s suicide is prohibited by s.2 of the Suicide Act 1961, as amended by the Coroners and Justice Act 2009
The Director of Public Prosecutions (DPP) examines individual cases to decide whether to prosecute. That decision is determined by offence-specific guidelines published in 2010.
A person judged to have assisted the suicide or attempted suicide of another person could face up to 14 years in prison. For euthanasia, the maximum penalty is life imprisonment.
In Northern Ireland:
Euthanasia is illegal and could be prosecuted as murder or manslaughter
‘Assisting or encouraging’ another person’s suicide is illegal under s.13 of the Criminal Justice (Northern Ireland) Act 1966, which extends the Suicide Act 1961 to Northern Ireland.
The Public Prosecution Service (PPS) examines individual cases to decide whether to prosecute. That decision is guided by offence-specific guidelines published in 2010.
In Scotland:
Euthanasia is illegal and could be prosecuted as murder or manslaughter.
There is no specific offence of assisting or encouraging suicide in Scotland. Any suspected offence would be dealt with under homicide law. The Crown Office and Procurator Fiscal Service (COPFS) makes the decision whether to prosecute.
There are no offence-specific guidelines in Scotland and the decision will be taken on the basis of the general prosecution code. A legal challenge to compel the COPFS to produce offence-specific guidelines failed in 2015.
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The future of euthanasia in the UK
Individuals and members of Parliament have tried to make the case for legalising euthanasia in the UK.
For example, in England and Wales, Baroness Meacher, a former social worker, crossbench peer and the Chair of Dignity in Dying, introduced a Private Members' Bill on assisted dying on 26 May 2021.
It was debated at its second reading in October that year, passing to Committee Stage. However, it ran out of time and was unable to pass all the required stages before the parliamentary session ended.
In Scotland, Scottish Liberal Democrat MSP Liam McArthur first lodged a Bill proposal on assisted dying in September 2021, lodging a final proposal in September 2022.
On the attitude towards legalising euthanasia in the UK, and whether it might happen, the BMJ states:
"Proponents of physician assisted dying, including The BMJ, claim that access to the option gives dying people choice and control over their death and can prevent intolerable and intractable suffering.
"But opponents fear consequences for vulnerable people, for society, and for the medical profession when doctors are permitted actively to induce death. The BMJ thinks it likely to be more a question of when, not if, assisted dying is legalised in the UK, and that all doctors should now engage with the debate.
"The BMJ continues to strive to represent all voices in the debate."