Euthanasia has more than one definition. Literally, euthanasia is painless killing of a patient who is suffering from an extremely painful disease and incurable or terminal ailment. It also applies to irreversible coma. Euthanasia is also referred to as mercy killing and assisted suicide. The assistance has to be provided by a physician or doctor. People in general cannot play a role in assisted suicide as euthanasia is physician assisted suicide. Beyond these broader definitions are the different types of euthanasia. There are active euthanasia and passive euthanasia. Active euthanasia is presently legal in Netherlands, Canada, Belgium, Luxembourg and Colombia. Assisted suicide or euthanasia is also legal in Germany, Switzerland and some states in America like Oregon, Washington, California, Hawaii, Colorado, Montana, Vermont and Washington D.C. Euthanasia has been legalised in the state of Victoria in Australia but it is poised to be in effect from mid 2019. Euthanasia remains illegal in Australia as per a federal law but states have the right to make their own laws.
Euthanasia in the Netherlands
The Netherlands was the first country in the world to legalise euthanasia. Assisted suicide and euthanasia have been legal since April, 2002. The law does have several conditions and some are quite stringent. A patient should be suffering unquestionably unbearable pain and the illness has to be incurable for the case to be even considered for euthanasia. There can be no exception to this rule. A patient should also be completely conscious at the time of choosing euthanasia. Patients who qualify for assisted suicide or euthanasia in the Netherlands are provided a lethal cocktail and the whole process is under medical supervision.
Palliative sedation has become common in the Netherlands in the last ten years. This is not the same as euthanasia by lethal cocktail. Patients who have less than two weeks to live can choose medically induced coma and their hydration & nutrition can be withdrawn. It should be noted that any kind of assisted suicide other than the grounds accounted for by the law is considered to be homicide. There are some organisations that educate people about euthanasia but they do not have any right to actually help people with assisted suicide.
Euthanasia in France
France is yet to legislate on euthanasia or assisted suicide. There have been sporadic movements and campaigns from time to time. More than one French president had promised to explore the premise of right to die with dignity but there has been no major effort to legislate. Some cases of securing the right to die with dignity have come to light over the years. A few of these cases did get some attention all over the country but there has been no impact on the stand of the lawmakers. French citizens do seek the intervention of the courts to be allowed to die with dignity. Some of these cases have been escalated to European Court of Human Rights as well. Decisions are awaited.
Euthanasia in the United States
Oregon was the first state in the United States to legislate on euthanasia and it effectively legalised assisted suicide in 1997. Euthanasia is illegal as per the federal law but states can have their distinct laws. Euthanasia is Oregon and other states in America, such as Washington, is strictly permitted for patients who are terminally ill. Patients who have fewer than six months or so to live can ask for lethal medication but they must be mentally competent to make a decision for themselves. Washington joined Oregon almost ten years later and in the last decade other states have come up with their own laws governing euthanasia. States like Vermont, Montana and New Mexico have now legalised euthanasia.
Euthanasia in Germany and Switzerland
Euthanasia is not referred to as such in Germany because Nazis had eugenicist policies so it is controversial. The terms used are assisted suicide and active assisted suicide or beihilfe zum suizid and aktive sterbehilfe respectively in German. The exact law is a little different in Switzerland and Germany than the ones in the United States, the Netherlands and other countries. Doctors in Germany cannot actually hand out the lethal medicine to a terminally ill patient. A doctor can provide guidance but not administer the lethal drug. Doctors in Switzerland can provide the lethal drug but there should not be any personal or self serving motive involved. If there is any motive or self interest then the doctor can be prosecuted.
Euthanasia in Belgium
Belgium legalised euthanasia in 2002. It was the second country after the Netherlands to legalise euthanasia. Terminally ill patients or those suffering from an incurable disease can express their desire to end their lives with dignity. Patients can also declare their will accordingly before getting into a coma so doctors can act as per their stated objective. In Belgium, the doctor or supervising physician must be present at the time of carrying out assisted suicide. The doctor must be at the bedside of the patient and should be there till the very end when the person takes the last breath. Doctors cannot give prescriptions and let patients be on their own in Belgium. This still happens in the state of Oregon in America and is not an illegal act there. Belgium has also legalised euthanasia for children. No specific age limit has been set to distinguish minors from adults. Belgium is the first country in the world to have done this.