Thursday, 3 August 2017

Suicide and Euthanasia - An Overview

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Expert Author Dhruv Desai
Legal jurisprudence states that there's a right and a corresponding responsibility to every motion and state of being inactive. And as all the rights that each person possesses within the cutting-edge society are being described to the finest volume, it is also equally actual that we lack a few provisions in our laws that might surely draw a stability between man or woman liberty and the affordable restraints of the kingdom and society. However, for this the nation has to recognize or understand the fact that not all matters are primarily based on cause or common sense; that we're people, who can not be ruled by mechanical legal guidelines.

Today there may be a developing debate over the rivalry, whether humans owning comparable rights- which includes the 'proper to live' additionally posses the 'right to die'. There is a divided opinion over this problem, as a few argue that lifestyles is to be persisted in every way possible- be it in a herbal or synthetic one. The rest agree with that it being a matter of individual liberty, each person are entitled to stay and quit our lives as and when we deem healthy. According to those people, suicide like euthanasia have to be morally permissible. Due regard need to take delivery of to each case of euthanasia earlier than a person's right to live and die a ache loose life is denied.

It is vital to draw a definitive line between suicide and euthanasia, where many are of the opinion that by means of allowing euthanasia we'd be in a roundabout way additionally be permitting suicide, consequently as against suicide the grounds on which euthanasia may be allowed must be very restrictive; and if at all allowed, be in exquisite cases, leaving no window for any mischief.

SUICIDE
Suicide as described in Webster's Dictionary approach an act or instance of intentionally killing oneself. Therefore, suicide will be termed because the intentional termination of 1's life via self- brought on means for diverse motives, inclusive of, frustration in love, failure in examinations or in getting an excellent process, however normally it's miles because of melancholy.

The genesis of the choice to stay or survive springs from the incentive to stay, which every man or women commonly posses. Such motivations may be numerous and may range from person to person. For existence it's miles imperative that each person has a purpose or motivation. But when such reasons or a motivation now not exist- along with it is going the mental purpose to exist. Therefore it would not be fake to say that our will power to exist is paramount to the whole thing else, even the laws that govern our lives.

Considering the above argument, it is still in the great interest of the society, that suicide now not be accepted, but disheartened the man or woman can be, because if authorized, it may have a bad effect at the minds of youngsters who for exceptional motives might also ponder suicide. Human existence is an enigma, wherein events and situations might also trade even in the blink of a watch. Therefore what may also appear to be a hopeless state of affairs nowadays, may well be really worth living day after today; and also because happiness like despair and disappointment is a nation of thoughts, that could change in keeping with circumstances that govern us.

In India, the Supreme Court has held , " The proper to live with dignity can not be construed to include inside its ambit the right o terminate natural lifestyles, at the least earlier than graduation of the herbal process of positive dying.

The Supreme Court of India in P. Rathinam's case found,
"The precept is that the sole give up for which mankind is warranted in my opinion or collectively, in interfering with the freedom of action of any in their number is self protection. That the simplest purpose for which electricity can be rightfully exercised over any member of a civilized network in opposition to his will is to prevent damage to others... In the element which merely concerns him, his independence, is of right, absolute."

But it changed into in Gian Kaur's case , which overruled P. Rathinam's case , the Supreme Court of India held, "Right to existence is a natural right embodied in Article 21 of the Constitution of India, however suicide is an unnatural termination or extinction of life and is incompatible and inconsistent with the concept of the proper to existence".

However, someone who has made up his mind and is determined to quit his existence in any respect expenses and no matter all repercussion that his actions may additionally have on those who care approximately him, cannot be stopped with the aid of regulation due to the fact he/she goes to cease his/her lifestyles sooner or later. As was discovered by means of the splendid truth seeker, poet 'Khalil Gibran' , "...You can muffle the drum and you may loosen the strings of the lyre, however who shall command the skylark no longer to sing?"

An English author- H. Romilly Fedden located , " It seems a vast technique to inflict in addition suffering on even a single character who has already observed life so insufferable, his possibilities of existence so slender, that he has been willing to stand pain and death which will cease his residing. That the ones for whom life is altogether sour must be subjected to similarly bitterness and degradation appears perverse law".

"The secular lives that most of us lead, no matter what our religion (or the dearth of it), can often hold us from seeking difficult answers to tough questions. There aren't any absolute requirements for steering. We are more likely to blur the troubles, no matter how well meaning, by way of appeals to what is sensible what works, or is value powerful, or suits our politics and what suits are open society. Most of all, it's about what suits us".

EUTHANASIA

Euthanasia or mercy killing is devoted on the premise of scientific reasons, where the demise of a terminally ill individual is brought approximately by using another person, who believes that such character's life is so awful that he/she could be better of useless; additionally whilst his movements are primarily based at the conviction that except he intervenes and ends the ill individual's lifestyles, it shall come to be so bad that he/she might be better of useless. Considering this remark, it may be stated that the purpose of the man or woman committing such acts of euthanasia is to benefit the one whose loss of life is delivered approximately.

The trouble of euthanasia has a protracted records of philosophical discussion. Ancient Greek thinkers appeared to have favoured euthanasia despite the fact that they antagonistic suicide. In medieval times Christian, Jewish and Muslim philosophers antagonistic lively euthanasia, despite the fact that the Christian Church has constantly familiar passive euthanasia.

In the sixteenth century, English Humanist Thomas More, in describing a utopian community, envisaged such a network as one that might facilitate the loss of life of these whose lives had come to be burdensome due to torturing and lingering ache. However, it has best been inside the ultimate one hundred years that there have been concerted efforts to make felony provisions for voluntary euthanasia.

Euthanasia may be categorised as:

1. Voluntary Euthanasia: Covers times of euthanasia in which a definitely competent man or woman makes voluntary and enduring request (either verbally or via a written file) to be helped to die. However, there's no unmarried, objectively accurate answer, which has utility to all and sundry, as to when if at all, lifestyles will become burdensome and unwanted. Where a significantly ill individual is normally in a significantly compromised and delibilated nation, it's far, different things being identical, the patients judgment of whether endured life is a advantage that need to bring the greatest weight, provided continually that the patient is competent.

In her judgment Judge Barbara Rothsein of the united statesDistrict Court held, "The struggling of a terminally ill individual cannot be deemed any much less intimate or personal, or any less deserving of safety from unwarranted governmental interference than that of a pregnant female... Just like the abortion choice, the selection of a terminally ill man or woman to cease his/her lifestyles includes the most intimate and private picks that someone could make in a life time; and constitutes a desire central to private dignity and autonomy. "

Considering the above, we are able to say that voluntary euthanasia is on the whole involved with the right to preference of the terminally unwell affected person who makes a decision to stop his or her life, desire which serves his/her first-rate hobby and also that of each person else.

Considering this the advocates of voluntary euthanasia have proposed certain restrictive situations, which contend that if the character is
a) affected by a terminal infection;
b) not going to be benefited from the invention of a remedy, for that infection in the course of what stays of his/her existence expectancy;
c) as an immediate result of the contamination, either suffering intolerable ache, or only has to be had a lifestyles this is unacceptably burdensome (due to the fact the infection must be handled in methods which cause her being unacceptably depending on others or on technological method of lifestyles support);
d) has a long lasting, voluntary and ready desire to die (or has prior to dropping the competency to do so, expressed a desire to die within the event that situations noted in a-c are satisfied; and
e) unable without assistance to devote suicide;
And in such instances most effective, there must be criminal and medical provisions to permit such individuals to be allowed to die or be assisted to die . (It is important to be aware right here that these conditions concern get admission to best to voluntary for those who are terminally unwell.) The first situation is restrictive within the feel that it allows simplest men and women who are terminally sick and not others which includes those affected by early Alzheimer's disorder, because the inclusion of such persons would, at the least at the moment make it some distance more difficult to reap legal sanction for supporting those affected by terminal contamination and want to die.

The second circumstance is supposed truly to reflect that miracle healing procedures, but sensationally spoken of, aren't so effortlessly to be had except there are painstaking breakthroughs finished. Which in truth are begotten via a totally long and gradual procedure of research. Therefore, within the gift situations at the least, it'd be very unfair to reject the appeals of such terminally ill folks, who desire to die.

The 0.33 circumstance acknowledges the fact that it now not only release from pain that leads such terminally ill folks to ask for euthanasia, due to the fact such humans can be relieved from the ache by management of medication, but, additionally they must bear the unsightly aspect consequences of such tablets. Whereas, some might not must deal with pain, alternatively are made incapable of living lifestyles with out life guide systems (eg: sufferers tormented by motor neurone sickness).

The fourth situation states that the selection to die no longer handiest be voluntary, but that it's made in an enduring manner and be competent. Also in cases where the patient be affected by depression, they have to be allowed a certain cooling off duration. The preference must be one that reflects will of the individual involved, require dialogue and time for mirrored image and have to not be settled in a second.

The reason there is massive divide over the granting of permission for exercise of voluntary euthanasia is stated to be the shortage of evidence, that can show that the death folks request to die is competent, enduring and honestly voluntary.

Also, in which someone is racked with ache or befuddled because of the measures taken to alleviate the ache; and isn't capable of assume truely and rationally about the options, such persons in the ones instances who want to die ought to now not be assumed to have a equipped, enduring and simply voluntary choice to die. In such instances, dwelling wills or improve declarations might be used as legal devices for giving voice to the needs of such humans. It is likewise now not vital for people to have suffered such infection; they are able to pen their mind on the basis of any earlier enjoy of contamination or deaths of the circle of relatives and friends.

The 5th condition further restricts get right of entry to to voluntary euthanasia by using apart from individuals who are sui juris or able to ending their own lives.

Moral Arguments for Voluntary Euthanasia

The vital moral argument for voluntary euthanasia- that respect for individuals demand, for their self reliant selections, so long as the ones alternatives do not bring about any damage to others, is immediately involved or connected with the difficulty of competence due to the fact autonomy presupposes competence.

Since dying is part of lifestyles, picks approximately the way of loss of life and the timing of death, are for plenty human beings, part of what's concerned in taking duty for his or her lives. Most people are concerned approximately what could the final segment of our lives be like. Not merely due to worry that our death may involve us in remarkable struggling, however also because of the preference to hold our dignity and as plenty control over our lives as feasible during this phase.

Voluntary euthanasia can be similarly classified into:

a) Passive Voluntary Euthanasia refers to cases wherein lifestyles sustaining or life prolonging measures are withdrawn or withheld, and steps that may keep or lengthen life are not taken, thereby allowing the patient to die.

B) Active Voluntary Euthanasia refers to cases in which energetic measures are taken to end the affected person's life, which includes via immediately administering a deadly dose of a drug.

The alleged distinction among passive and lively voluntary euthanasia, is typically a remember of pragmastics, now not of whatever of deeper importance. For example do not forget the practice of deliberately intending slowly closer to a ward in response to request to provide assistance for a patient who's problem to a not for resuscitation code. Or keep in mind pulling the plug on an oxygen machine maintaining and in any other case loss of life affected person alive, as in opposition to now not changing the tank while it runs out.

According to James Rachels (Professor of Philosophy on the University of Alabama), "There is no ethical difference between actively killing a affected person and passively permitting a patient to die."
He in addition states that the strategies of passive euthanasia extend the struggling of the patient, for it takes longer to passively allow the patient to die than it would if active measures have been to be taken; and within the imply time the patient is in insufferable ache. Since the choice has to be made to convey an in advance death, it is as an alternative cruel to adopt the longer technique.
Also, passive and active euthanasia do not vary considering that both have the same final results- the dying of the patient on humanitarian grounds. The distinction between the 2 is accentuated due to the fact we often listen of horrible cases of energetic killings, however no longer of passive killings.

It is frequently said that despite the fact that purpose and results are agreed to be in not unusual, if a person's existence is deliberately terminated, he/she has been killed, whereas, if he/she is no longer being aggressively handled his/her lifestyles isn't always ended by way of the with drawl of such competitive remedy, but because of the underlying ailment.

2. Non-Voluntary Euthanasia: Includes times wherein someone is either no longer competent to or unable to, express a desire approximately euthanasia, or wherein the affected person is subconscious, comatose, or is in any other case not able to explicitly make his/her intentions recognized; and there may be no one legal to make a substituted judgment (in which a proxy might choose, because the not able affected person might have selected).

In voluntary euthanasia, the patient has had on previous event, given boost directives in the shape of dwelling wills (or otherwise) to express his preference or want in instances in which he himself isn't in a function to present this type of directives. Whereas in Non-Voluntary euthanasia the patient has left no such living will or given any advance directives, as he won't have had an possibility to accomplish that, or may not have expected this sort of coincidence or eventuality. In cases of non voluntary euthanasia, it's far often the family members who make the selection, while in The Netherlands, it's far the Doctors who usually decide whether or not the patients' life is to be terminated or now not. However, there are sure prison hints that additionally they must follow for terminating the patient's existence.

However, today there is also a developing worry among humans that by way of permitting voluntary euthanasia to be legally permitted, we may additionally set foot on a slippery foot that may lead us necessarily to help other types of euthanasia, specifically non-voluntary euthanasia. The arguments touching on the permissibility of non-voluntary euthanasia are primarily based on:
a) Psychological, b) logical; and c) arbitrary lines.

A) Psychological Basis: With regard to the mental inevitability, there may be no manner of knowing the sufferers views, due to the fact the patient is neither capable, nor has made any provision for a proxy to make a substituted judgment. And those who price the autonomy of the indivisual and support the provisions for voluntary euthanasia can not be presumed to discover it psychologically simpler (as there's no purpose to believe that they will) to kill patients who aren't capable competently to request help with dying.

B) Logical Basis: There is nothing logically inconsistent in assisting voluntary euthanasia

but rejecting non-voluntary euthanasia as morally inappropriate. The two problems being

logically separate there may be some advocates of voluntary euthanasia who want to lent

their aid to a few acts of non-voluntary euthanasia. (eg. Those in Persistent

Vegetative State who by no means indicated their wishes or folks who by no means anticipated

such eventuality.) Others might imagine that what can be achieved with the consent of the

patient sets a limit on the exercise of euthanasia. The difference therefore isn't of

logical acumen, however has to be located in the respective values of various supporters.

B) Arbitrary Basis: There can be no substance to the price that there's a slide from

voluntary euthanasia to non-voluntary (as the line between them is based totally on clean

ideas).

After the book of the Remmelink Report within the 1991 into the medical practice of euthanasia in The Netherlands, it has often been said that the Dutch enjoy indicates decisively that legally protecting voluntary euthanasia is impossible with out also affording safety to non- voluntary euthanasia so one can are available its educate... In a 2d kingdom huge research of doctor assisted dying in The Netherlands achieved in 1995 a comparable photo emerged as had within the Remmelink Report of 1991. But again no proof turned into found of any respectable down a slippery slope towards ignoring human beings's voluntary picks to be assisted to die.

"If lively euthanasia is widely practiced but in ways that are not legally diagnosed, there's apt in fact to be more danger that the distinction between voluntary cases and non-voluntary instances might be blurred or neglected than in a scenario where the sporting out of euthanasia is obvious and concern to tracking ."

Therefore, at the same time as permitting voluntary euthanasia, it's also important that safeguards be put in opposition to ability abuse of any legal safety for voluntary euthanasia. One effective approach for safety is that of improve directives like living wills, that are thought to be widely powerful, if no longer best.

3. In-Voluntary Euthanasia: In-Voluntary Euthanasia refers t cases wherein a equipped affected person's life is added to an cease against the desires of that affected person that oppose euthanasia; and might actually quantity to murder. In such cases, irrespective of how honourable the wrongdoer's motive, such form of euthanasia must be illegal.

The Medical Profession And Euthanasia

Theoretically talking, medical specialists have several alternatives open to them in instances wherein the patient is terminally unwell, or in extreme ache, or voluntarily chooses to stop his own life to escape the lengthen struggling. These alternatives are: a) The worker can forget about the patient's request b) The clinical employees can discontinue offering remedy to permit the patient to die (Passive Euthanasia) c) The scientific employees can provide the patient with the approach to cease his own lifestyles (Assisted Suicide) or d) Take active measures to stop the patient's life (Active Euthanasia).

However, the cost (or proper) of self-willpower does not entitle a patient to compel a scientific professional to behave opposite to his/her moral or professional values. If voluntary euthanasia is legally authorised, it ought to additionally be towards a backdrop of admire for professional autonomy.

Euthanasia And Laws Pertaining To Euthanasia In Different Countries

1. The Netherlands: In the 19 seventies and eighties a chain of court instances in The Netherlands culminated in an settlement being reached among the legal and clinical government to make certain that no doctor could be prosecuted for supporting a affected person to die so long as certain suggestions were strictly adhered to. These pointers were established to allow physicians to practice voluntary euthanasia in instances in which: a) A capable patient had made a voluntary; and informed selection to die. B) The patient's suffering become unbearable. C) there has been no way of creating that struggling bearable which became ideal to the patient. D) The doctor's judgment as to the analysis and prognosis were showed after session with every other physician. In November 2000, The Netherlands passed a legislation to legalize the exercise of voluntary euthanasia. The rules surpassed thru all Parliamentary ranges; and in early 2001 have become Law. Since 2001 many patients laid low with numerous incurable illnesses had been able to put an stop to their misery by means of opting for euthanasia.

2. U.S.A: In Oregon, law changed into added in 1997, to allow medical doctor assisted suicide, while a second referendum really recommended the proposed regulation. Later, in 1997 the Supreme Court of U.S in two sizeable instances dominated that, "There isn't any constitutional right to physician assisted suicide. " However, the Court did now not avert man or woman States from legalizing in favour of health practitioner-assisted suicide. As a result the Oregon law continues to be operative and keeps to serve the motive of many people. In Florida the legislators debated the issue of Terri Schiavo, who were in Persistent Vegetative State for the past fifteen years and had not left any boost directives with the assist of which the problem could have been effortlessly resolved. Her husband sought to have her feeding tube withdrawn; and had won the Courts approval to achieve this. However, Mrs. Shiavo's dad and mom opposed the said choice of the Court. Meanwhile the Florida legislature hastily enacted a regulation directing that the feeding tube be implemented once more. In this unique case, many are of the opinion that after fifteen years in a continual vegetative nation, perhaps Mrs. Schiavo have to be allowed to die.

The Iowa Law Review in October, 1989 posted a "Model Aid-In Dying Act", beneath which even a child above the 'age of six' may want to request Aid-in-Dying; and if his parents refused to permit him, an "Aid-in-Dying Board" should overrule them and grant the request.
In 1984 the then Governor of Colorado - Richard Lamm said , "The terminally sick elders have a duty to die and get out of the way."

Jack Kevorkian also called the 'Doctor of Death' in his trial in Michigan stated, "If a rational policy of deliberate demise can be attained, the gain for the society is incalculable ." Also there are many who're of the opinion that euthanasia may also be used to get rid of the defective to be able to support the gene pool, or to hold the developing population underneath check; and for that reason be very useful for the society. But such excessive measures are possibly too irrational.

In the U.S, in instances which include Nancy Cruzan , John Doe , and that of Karen Ann Quinlan, that Supreme Court has time and again reiterated its view that, though there's a Constitutionally protected 'proper to die,' this proper isn't absolute, for the State has an hobby in protecting and maintaining life.
Today in America, various offers are being made to sell euthanasia by numerous foundations. Also, education applications are being designed to train clinical personnel in the pro-euthanasia newspeak.

3. Australia: In the 19 nineties in Australia, the primary legislative approval for voluntary euthanasia turned into completed with the passage of a invoice within the Parliament of Australia's Northern Territory to enable physicians to exercise voluntary euthanasia. Subsequent to the Rights of the Terminally Ill Act's Proclamation in 1996, it confronted a sequence of demanding situations from fighters of voluntary euthanasia. In 1997, the demanding situations culminated within the Australian National Parliament overturning the regulation; and prohibiting Australian Territories (The Australian Capital Territory and The Northern Territory) from enacting any regulation permitting euthanasia.
It turned into observed in an Australian case , "The Rights of the Terminally Ill Act (as amended) (NT) is specific. It is sui generis. It is a composite whole. It establishes a regulatory regime for the intentional termination of human existence in stipulated situations. In doing so, it eliminates all crook, civil and professional sanctions otherwise applicable to a medical practitioner who deliberately terminates a affected person's lifestyles or aids a affected person to commit suicide according with stipulated techniques. The Act institutionalises intentional killing which might otherwise be murder; it institutionalises assisting suicide which would otherwise be a criminal offense."

It become about a 12 months ago, when an Australian citizen devised an tool able to conserving carbon monoxide gasoline; it was made especially for individuals who wanted to put an quit to their lives, while not having to endure any pain inside the manner.

4. Belgium: The Belgian Parliament rules favouring euthanasia in May, 2002 quite similar to that exceeded in The Netherlands. And inside the first year of its legalization, 203 instances have been recorded, in keeping with the newly released figures provided by the Public Health Ministry. The Public Health Ministry is now analyzing how patients and docs are informed about this issue in The Netherlands in comparison to Belgium; also modifications to assessments on compliance with the legal conditions beneath which euthanasia is achieved are also being considered, as are less difficult registration forms. Recently there was a forum held through Doctors in Brussels, wherein the medical doctors admitted that there might be more than thousand deaths yearly thru euthanasia in very first year of its being legalized, a leading spokesman opined that the practice of euthanasia must be improved to encompass teenagers and more disabled humans .

Summary

Some argue that individuals worrying the permissibility of euthanasia are folks that, perhaps because of a critical contamination or perhaps for purpose unrelated to their infection are extraordinarily depressed and say that they need to die. That these humans are not any distinctive than others who think about suicide- simply that they have scientific issues in addition to their emotional or mental problems. Most folks are victims of frustration, due to the fact they find themselves on this entire new international, wherein they may be absolutely dependent on others and locate it not possible to guide any active life for that depend. Suicidologists locate that folks who speak of suicide or ending their lifestyles accomplish that, due to the fact they desire to are trying to find interest. But the prevailing argument isn't directed toward determining whether persons needing attention ought to accept such interest. The present argument prominently concerns itself with the issue, which is connected without delay to every one folks. It speaks of the rights of those individuals who are terminally ill (just like the right to decide about lifestyles sustaining treatment; and proper to respect for autonomy) and have no- wherein to head or seek, but the Court of Law and Justice, due to the fact ultra-modern and with a bit of luck day after today's international is based and managed with the aid of the rule of thumb of regulation. However the simplest contribution that the regulation can make at this juncture is offering a procedural legal framework that could manual the practice of euthanasia (in the first-rate viable manner) in serving the interests of the cutting-edge and future society.

Also, euthanasia and health practitioner assisted suicide are not truly prison problems on my own; and by terming them as felony questions, we can be lacking the crux of the matter. With normal discoveries being made in present day science and remedy, new methods to sustain and extend existence are delivered about, retaining us alive no matter what. But unless modern technological know-how and medication provide you with a miracle treatment for age, that could maintain us alive and active, increasingly more people inclusive of the ones laid low with Aids, Cancer, or sufferers in Persistent Vegetative State, or patients laid low with motor neurone disorder, could rather prefer to exercise the choice of euthanasia and medical doctor assisted suicide.

Whilst most of the scientific facilities within the United States and that of a number of the most developed countries observe the request of the patient in the shape of Do Not Resuscitate (DNR) why then is it tough to permit a person to chose the way wherein he/she dies. Everyday, we make lots of exceptions each massive and small, many even with out our information. Perhaps it's time we made one towards our coverage for euthanasia in extremely good cases of the terminally sick patients, who desire to die.

Citations

1. Webster's Dictionary (II) New Riverside University pg. 1159
2. Gian Kaur v. State of Punjab (1996) 2 SCC 648
3. P. Rathinam v. Union of India (1994) three SCC 394
four. Ibid
five. Ibid
6. The Prophet - Great Works Of Khalil Gibran
7. Suicide (London 1938), pg. Forty two
8. Suzanne Fields 'The Washington Times' October 27, 2003
9. Compassion in Dying v. Washington, Filed March 6, (1996) U.S Court of Appeals ninth Circuit Court.
10. Robert Young "Voluntary Euthanasia"- Stanford Encyclopedia of Philosophy. April 18, (1996-a)
11. "Active and Passive Euthanasia" The New England Journal of Medicine, Vol. 292 January 9, 1975, pp. 78-80
12. Robert Young "Voluntary Euthanasia"- Stanford Encyclopedia of Philosophy. April 18, (1996-b)
thirteen. Robert Young "Voluntary Euthanasia"- Stanford Encyclopedia of Philosophy. April 18, (1996-c)
14. Washington v. Glucksberg, 521 U.S 702 (1997
15. Quill v. Vacco, 521 U.S 793 (1997)
16. Death With Dignity Act, 1997
17. New York Times, 29 March 1984
18. Michigan v. Kevorkian, Oakland Circuit Court, ninth June 1990.
19. Cruzan v. Director, MDH, 497 U.S 261 (1990)
20. Compassion in Dying v. Washington, Filed March 6, 1996 (U.S Court of Appeals) ninth Circuit Court.
21. Source: World Magazine February, 1999
22. Euthanasia Laws Bill, 1996 (The Andrew's Bill)
23. Christopher John Wake and Djiniyini Ggondarra v. Northern Territory of Australia (1996) five NTLR one hundred seventy
24. Source: Belgian News November 25, 2003
25. Steven   Brussels, Belgium December 8, 2003
26. (1987) Cr LJ 549
27. (1994) three SCC 394
28. Gian Kaur v. State of Punjab (1996) 2 SCC 648
29. (1994) 3 SCC 394

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