Assisted dying: what is the law in other countries?

This Friday, parliamentarians will have to make one of the most important choices in their careers – whether to vote for assisted dying.

The purpose of the bill is to ensure that adults who are mentally competent, over 18 years of age, have a terminal illness and within the last six months of their life can seek medical assistance in the event of death.

In England and Wales it is illegal to encourage or assist another person to commit suicide (or attempt suicide) under section 2(1). 1 Suicide Act 1961

According to Ms Leadbeater, the current framework must be changed because the only options available to terminally ill and suffering people are “suicide, suffering or Switzerland”.

If England and Wales go ahead with this proposal, they will not be the first. Which other countries have approved assisted dying and what have been the consequences for them?

Dame Esther Rantzen has revealed she has joined dying charity Dignitas (Jonathan Brady/PA)

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When Switzerland legalized assisted suicide in 1942, it became the first country in the world to establish a “right to die.” It is one of the few countries that provide foreigners with access to death support through institutions such as Dignitas in Zurich.

In Switzerland, the medicine must be self-administered.

Parents must participate in the decision-making process, but theoretically 16- and 17-year-olds do not require parental consent. Young people can request euthanasia from the age of 18 without parental consent.

Belgium has allowed assisted dying since 2002 for adults and children. Patients must suffer from a serious, incurable disease that causes them to endure excruciating, unrelenting physical or mental pain.

Euthanasia and assisted suicide have been legal in Luxembourg since 2009. Patients must have an incurable disease, be mentally competent and regularly experience excruciating physical or mental pain. They also need consent from two doctors and a group of experts, and must repeatedly ask for death.

Assisted dying in Spain became legal in the country in 2021. Assisted dying requests are open to anyone who has a serious, chronic and incapacitating illness or condition that has left the patient with no hope of recovery. The law does not distinguish between mental and physical disorders.

To be eligible for assisted dying, a patient must consult a doctor and submit two written requests. The application can then be approved by the regional commission of specialists.

Assisted suicide is legal in Austria from 2022, but only under certain health conditions.

Before 2022, Austria had some of the strictest laws on assisted suicide. This system was unique in that it prohibited its residents from helping other citizens commit suicide abroad.

The Austrian ban was considered by the Austrian authorities to be too strict and in violation of the right to self-determination Austrian Constitutional Court in 2020. As a result of this ruling, a new law was created.

As in Switzerland, medications must be self-administered.

The Isle of Man Parliament has almost completed legislation that would allow terminally ill adults with 12 months to live to be assisted in dying.

The bill is expected to receive royal assent next year, and the first cases of assisted deaths could occur in 2027. There is a five-year residence requirement.

For terminally ill patients, Jersey has also committed to changing the law to allow assisted suicide.

Ten states in the US have legalized it, including Washington assisted suicide. With more than 25 years of experience, Oregon was one of the first jurisdictions in the world to provide assistance in dying to some patients in 1997. It is now used as a model for other assisted suicide laws in the United States.

In Oregon, people who are terminally ill, intellectually competent, and likely to die within six months are eligible for assisted dying; however, the procedure must be approved by two doctors.

External medical assistance in dying was first made available to terminally ill people in 2016. This option was changed in 2021 to cover anyone experiencing “unbearable suffering” as a result of a terminal illness or disability.

Despite delays, it is still expected to be available to people with mental illness in three years.

Australia and New Zealand

Majority Australia in recent years it has legalized assisted dying. In eligible regions of Australia, this period is extended to 12 months for people with a neurological condition.

IN New Zealandpatients must be terminally ill and expected to die within six months.

In both countries, the medicine can be used by patients themselves. The medicine may also be given by a doctor or nurse, usually by injection into a vein.