Across Europe, six countries have some form of legalised assisted dying: Switzerland, the Netherlands, Belgium, Luxembourg, Spain and Austria. In all of them – unlike the proposals in England and Wales – help to die is not restricted to the terminally ill.
Switzerland was the first country in the world to create a “right to die” when it made assisted suicide legal in 1942. It is one of the few countries which allows foreigners access to help to die via organisations like Dignitas, in Zurich. More than 600 Britons have died at Dignitas, external in the past two decades, including 43 last year. The lethal medication must be self-administered.
The Netherlands and Belgium both legalised assisted dying more than 20 years ago for patients experiencing unbearable suffering from an incurable illness, including mental health issues. It has since been extended to children – the only European countries to allow this. Both allow euthanasia – or physician-assisted dying.
Most recently, Spain and Austria have legalised assisted dying for both terminal illness and intolerable suffering. In Austria, the drugs must be self-administered, whereas in Spain a medical professional can administer them.
MPs are debating again proposals to legalise assisted dying in England and Wales.
Assisted dying has already been legalised in one part of the British Isles.
In July, Royal Assent was given to a bill in Jersey. Unlike at Westminster and Holyrood, the legislation was introduced by the Jersey government, which says it will take about 18 months to set up the service. The first assisted death could happen late next year. There will be a residency requirement of one year, in a bid to prevent so-called ‘death tourism’.
The measure, which most sets apart the Jersey legislation from the rest of the British Isles, concerns the manner in which those eligible for an assisted death can end their lives.
Individuals will be able to choose to have a doctor administer a lethal dose intravenously, as happens in Spain, Canada, New Zealand and most of Australia.
This is, in effect, voluntary euthanasia. It has become the preferred method of assisted dying in jurisdictions which allow this choice.
The laws proposed at Westminster, Holyrood and Tynwald – Isle of Man – all state that death must be by self-administration, which usually means the individual swallowing a lethal dose.
The Isle of Man assisted dying bill was passed by Tynwald (the Manx parliament) in March last year. As a UK Crown Dependency – like Jersey – it could not become law until granted Royal Assent.
This was declined earlier this year by the UK Ministry of Justice, but Tynwald has since passed an updated bill which has been sent back to the UK government for a second time.
If Royal Assent is granted, the Isle of Man expects the service to be operational next year. There is a residency requirement of five years.
