The offensive of assisted suicide and euthanasia in Great Britain and in France
Bills aimed at legislating on the administration of death induced by assisted suicide or euthanasia are being debated in Great Britain and in France. Opposition is making itself heard in both countries with regard to the risks for the most vulnerable.
In Great Britain, a new stage will be reached in the coming days with a new debate on amendments in the House of Commons on 13th June and a vote on 20th June. If the “Terminally Ill Adults (End of life) Bill” is adopted, it would then be transferred to the House of Lords.
The law would be applicable in England. For Wales, a vote would be required at the Senedd, the Welsh Parliament which has already voted against it. Scotland is also examining a similar bill, which, in order to be accepted, would require acceptance by Westminster.
What are the differences between the bills in Great Britain and in France ?
| England / Wales | France |
| Assisted death | Assistance in dying |
| Assisted suicide: the patient self-administers the lethal product |
Assisted suicide in the first instance: the patient self-administers the lethal product Euthanasia: a doctor or nurse administers the product if the patient is physically incapable of so doing |
| Must be an adult, living in England or in Wales and must have been registered with a general practitioner during the last 12 months. | Must be an adult including under legal protection, must have French nationality or be living stably and legally in France. |
| Must be suffering from an incurable disease with a life expectancy of 6 months |
Be suffering from “a serious and incurable disease, for whatever cause, which affects life expectancy, in an advanced or terminal phase”. Being subject to “constant physical or psychological suffering” which is “either refractory to treatments, or unbearable according to the person” when he/she “chooses not to receive or to terminate” a treatment. |
| Must have the mental capacity to make choices and be reputed to have expressed a clear, established and enlightened will, and free of any coercion or pressure. | Must be “apt to express his/her free and enlightened will”. |
| Must submit two distinct declarations in writing, signed and certified, concerning the wish to die. | The patient must submit a request in writing or by any other means if he/she is unable to write. |
| Respect a 14-day interval between the approval of the request and the execution of the assisted suicide. | Respect a 48-hour interval between the approval of the request and the execution of the assisted suicide or euthanasia. |
| Penalty of 14 years in prison for any person compelling someone to declare that he/she wishes to end his/her days |
No penalty for incitement. Penalty of 2 years in prison and 30,000 euros fine for anyone attempting to prevent an assisted suicide or euthanasia. |
|
Conscience clause For all health professionals including chemists. A doctor is not obliged to take part nor to refer the patient to another doctor but must ensure that the person can obtain all necessary information during the first interview. |
Conscience clause For professionals (doctors or nurses) who take an active part in the process. The doctor is however bound not to attempt to dissuade the patient, and must redirect the patient to another doctor if necessary. Moreover, chemists and institutions are denied any conscience clause. |
The modifications being debated for the British bill
According to the initial proposals, a High Court judge would have had to approve every request for assisted suicide. However, an amendment by reporter Leadbeater was adopted such that a panel of three people consisting of a jurist, a psychiatrist and a social worker, will have to approve the request. This amendment has led to certain undecided MPs to change their position due to the lack of safeguards.
Other changes were also adopted at this stage. They concern the delay for entry into effect of the bill which increases from two to four years after the adoption of the bill to allow for finalising and the establishment of the system, the application of a conscience clause for health professionals as well as the proposal of access to palliative care during a consultation for assisted suicide.
Increasing objections
The English bill (Terminally Ill Adults Bill), although more restrictive than the French bill adopted by the National Assembly at its first reading, remains highly controversial at a time when the health system (NHS) – like in France – is deteriorating and one in four patients have no access to palliative care.
Objections are increasing in both countries on the lack of safeguards and on the endangering of the most vulnerable. Several British MPs are alarmed and could change their vote. In France, following the example of other personalities, the recent address by Jacques Attali is also an example. Although he was among those who would have wished to be able to support the text, he says he is opposed to the bill in spite of his ultra-liberal convictions on the subject: “Nothing guarantees […] that we will not see in France the same evolution as that which seems to be developing in other states where such a law exists, in particular in Canada and Holland, where this possibility seems at the moment to be used especially by the poor and the most vulnerable”.
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