Members of parliament will have to make one of the most important choices of their careers this Friday – whether or not to vote in favour of assisted dying.
The bill’s goal is to give adults who are mentally capable, are at least 18 years old, terminally sick and in the last six months of their lives the ability to request assistance from a doctor to die.
In England and Wales, encouraging or aiding someone else’s suicide (or attempted suicide) is illegal under section 2(1) of the Suicide Act 1961.
The current framework, according to Ms Leadbeater, needs to change because the only options available to terminally sick and suffering individuals are “suicide, suffering, or Switzerland”.
If England and Wales go ahead with the proposal, they won’t be the first. Which other countries have approved assisted dying and what have been the consequences for them?
Dame Esther Rantzen revealed she had joined assisted dying organisation Dignitas (Jonathan Brady/PA)
PA Archive
When Switzerland legalised assisted suicide in 1942, it became the first nation in the world to establish a “right to die”. It is among the few nations that provide foreigners with access to death support through institutions like Zurich’s Dignitas.
The drug must be self-administered in Switzerland.
Parents must participate in the decision-making process, but in theory, 16 and 17-year-olds do not require parental consent. Without parental consent, young individuals have the ability to request euthanasia starting at age 18.
Belgium has allowed assisted dying since 2002 for adults and children. Patients must be suffering from a serious, incurable illness that is causing them to endure excruciating physical or mental pain that is unabated.
Euthanasia and assisted suicide has been legal in Luxembourg since 2009. Patients must suffer from an incurable illness, be mentally competent, and experience excruciating bodily or mental agony on a regular basis. They also need the approval of two physicians and a group of experts, and must make repeated requests to die.
Assisted dying in Spain became legal in the country in 2021. Requests for assisted dying are open to anyone with a serious, chronic and incapacitating sickness or condition that has left the patient with no hope of recovery. A distinction between mental and physical disorders is not made by the law.
A patient must consult medical doctors and make two written petitions to be considered for assisted dying. After that, the request can be approved by a regional committee of specialists.
Assisted suicide has been legal in Austria since 2022 but only under certain health conditions.
Before 2022, one of the strictest laws on suicide aid was in place in Austria. This system was unique in that it forbade its residents from aiding other nationals in committing suicide overseas.
The Austrian prohibition was deemed excessively severe and in violation of the right to self-determination by the Austrian Constitutional Court in 2020. The new law was created as a result of that ruling.
As with Switzerland, the drugs must be self-administered.
The Isle of Man parliament has almost finished a law that will permit terminally ill adults who have 12 months or less to live to be given assistance to die.
Next year, the law is expected to receive royal assent and in 2027 the first assisted deaths may take place. There is a five-year residence requirement.
For terminally sick patients, Jersey has also pledged to amend the law to permit assisted suicide.
Ten states in the US, including Washington DC, have legalised assisted suicide. With more than 25 years of expertise, Oregon was among the first jurisdictions in the world to provide assistance to die for certain patients in 1997. It is now used as a template for other assisted suicide laws in the United States.
In Oregon, terminally ill, intellectually competent individuals who are expected to pass away within six months are eligible for assisted dying; however, two doctors must approve the procedure.
External medical assistance in dying was first made available to the terminally ill in 2016. In 2021, this was changed to include anyone going through “unbearable suffering” as a result of an irreparable disease or disability.
Despite delays, it is still scheduled to be accessible to people with mental illnesses in three years.
Australia and New Zealand
Most of Australia has legalised assisted dying in recent years. In eligible regions of Australia, that is increased to 12 months for people with neurological diseases.
In New Zealand, patients must be terminally sick and expected to die within six months.
The drug can be self-administered by patients in both countries. A physician or nurse may also deliver it, typically by intravenous injection.
