Euthanasia in International and comparative perspective

Euthanasia probably is one of the most natural issues to study in a comparative way. Unlike some of the other ‘classical’ crimes - such as murder, theft and arson – it is a centrepiece of controversy in quite a few countries. This is evidenced by the fact that in most countries there has been heated doctrinal debate on the admissibility of certain kinds and types of euthanasia. Furthermore, in many jurisdictions case law has provided guidance when statutory law was found to be too restrictive to suit the needs of extraordinary situations. A brief glimpse of academic writings and case law in various jurisdictions suffices to confirm that the stakes are high in this area. We are dealing with the right to life on the one hand and the right to die with dignity on the other. Maybe the individual human beings’ right to self-determination should even be included in the equation. It is quite a balancing act which is required from the lawmaker, from law enforcement officials and from the judiciary. Hence it is not surprising, that different jurisdictions have found different solutions to the problem at hand.No less than 14 national reports were submitted for discussion during the Congress in Utrecht. Together with the general report they are published in this volume.Contents Preface Euthanasia and the criminal justice system General report on the state of the art in 14 jurisdictions, Marc Groenhuijsen Euthanasia in BELGIUM, Walter De Bondt & Thierry Vansweevelt Euthanasia in CROATIA, Ksenija Turkovic Euthanasia in FINLAND, Raimo Lahti L’euthanasie en droit français (FRANCE), Christian Byk Euthanasia in GERMANY, Torsten Verrel Euthanasia in the domestic legal system of GREECE, Elisavet Symeonidou-Kastanidou L’Euthanasie en IRAN, Iradj Goldouzian Euthanasia in ISRAEL, Ruth Kannai & Lea Vizel Euthanasia in ITALY, Francesco Viganò Euthanasia in Japanese law (JAPAN), Katsunori Kai Euthanasia in the broader framework of Dutch penal policies (THE NETHERLANDS), Marc Groenhuijsen & Floris van Laanen Euthanasia in POLAND, Witold Kulesza Euthanasia in the Spanish legal system (SPAIN), Nuria Pastor Muñoz Causing Death for Compassionate Reasons in American Law (UNITED STATES OF AMERICA), Richard S. Kay