The broadcaster and Silver Line founder Esther Rantzen has said she has considered the option of assisted dying if her ongoing lung cancer treatment does not improve her condition, adding that she had joined the Swiss organisation Dignitas, which offers physician-assisted suicide. Here we take a look at the policies of other countries.
Canada
Doctors are permitted to prescribe drugs for self-administration and they have been able to administer them since 2021 to those who ask to die and have a grievous and irremediable medical condition. A ban on assisted dying was liberalised after a 2015 supreme court ruling that prohibiting a physician’s assistance in terminating life infringed on the constitutional right to life, liberty and the security of the person who required such help.
Netherlands
The Termination of Life on Request and Assisted Suicide Act 2001 permits doctors to prescribe drugs for self-administration and to administer where it can be shown that the individual concerned is experiencing unbearable suffering and is making an informed choice to die. The individual involved must be at least 12 years old and parental consent is required for those aged 12-16.
Switzerland
The Swiss Criminal Code of 1942 permitted adults to assist in another’s suicide as long as the motive for doing so was not “selfish”. Doctors are permitted to prescribe drugs for self-administration and to administer. Organisations providing assisted suicide have been providing services under certain regulations since 1985. Assisted suicide is lawful irrespective of the condition of the person who requests it.
Germany
Lawmakers are struggling to agree on new legislation after a 2020 federal constitutional court ruling that a ban on assisted suicide violated the rights of citizens to determine the circumstances of their death by restricting their ability to seek assistance from a third party.
US
Medically assisted dying for adults is legal in 11 of the 50 states. In Washington DC, the Death With Dignity Act 2016 permits doctors to prescribe drugs for self-administration. Legislation was passed this year to allow more types of healthcare providers in the district to sign off on requests for a medically assisted death, and allow the drugs to be mailed to patients instead of collected in person.
Australia
In Victoria, Western Australia, Tasmania, South Australia, Queensland, and New South Wales, doctors are able to prescribe drugs to adults for self-administration and, in cases where an individual is physically unable to self-administer, to administer the drugs. Assisted dying remains illegal in the Northern Territory and the Australian Capital Territory (ACT). A bill to legalise voluntary assisted dying in the ACT was introduced to the legislative assembly in October.
Belgium
For the past 20 years under Belgian law, patients have qualified for medically assisted dying if they have an incurable illness and experience constant and intolerable suffering that cannot be alleviated. Unlike in many other countries with liberal legal systems, euthanasia for people who are not terminally ill, such as those with psychiatric disorders or dementia, is also legal. Since 2014 there have been no age restrictions; parental consent is required for under-18s.
France
This year, President Emmanuel Macron instructed the government to look at whether euthanasia or assisted dying should be permitted in France. The law, in effect since 2016, allows medical personnel to place someone close to death and in intolerable pain under permanent sedation but stops short of authorising them to administer or supply a lethal substance.
Japan
According to Japan’s penal code, solicitation of suicide (the act of intentionally killing oneself), assistance in suicide, commissioned murder and consensual homicide are illegal. No laws or official guidelines govern voluntary assisted dying.
• This article was amended on 20 December 2023 to correct the number of US states from 52 to 50.
