JAMIA MILLIA ISLAMIA UNIVERSITY

LAW AND POVERTY

RIGHT TO DIE

SUBMITTED TO:- MR.RASHEED CA

SUBMITTED BY:- UMANG DIXIT

BALLB (HONS)(REGULAR)
2ND YEAR

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ACKNOWLEDGEMENT

This Project couldn’t have been successfully completed without the support and guidance of
our Law &Poverty Assistant Professor, “ Mr. Rasheed CA” Sir and we would like to express
our immense gratitude to him for his constant support and motivation that has encouraged us
to come up with this project. We are also thankful to our librarian for the support rendered
during the course of the research.

Umang Dixit

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TABLE OF CONTENTS

SERIAL TOPIC PAGE

NO.
NO.
1. INTRODUCTION 5
2. LITERATURE REVIEW 6
3. SYNOPSIS 7
4.  STATEMENT OF PROBLEM 9
 METHODOLOGY
 OBJECTIVES
 HYPOTHESIS
 RESEARCH QUESTIONS

CHAPTERISATION

5.  CHAPTER 1:DEFINATION OF 10-15

EUTHANASIA AND ITS TYPES.
10
 CHAPTER 2:VOLUNTARY DEATH
FROM RELIGIOUS PERSPECTIVE.
 CHAPTER 3:POSITION OF 11
EUTHANASIA IN OTHER COUNTRIES.
12

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 CHAPTER 4:ARGUMENTS IN FAVOUR

OF LEGALIZING EUTHANASIA.
14
 CHAPTER 5:ARGUMENTS AGAINST
LEGALIZING EUTHANASIA.
15

CONCLUSION 16
6. BIBLIOGRAPHY
17
7. 18

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INTRODUCTION

Part III of Indian Constitution contains a long list of fundamental rights. What's more, one of
the real key rights among them is Article 21. This article 21 of our constitution manages
"Protection of Life and Personal Liberty".

The Article 211 read as under: "No person shall be deprived of his life or personal liberty
except according to procedure established by law."

As indicated by this article appropriate to life implies the privilege to lead important, finish
and stately life. The question of the basic directly under Article 21 is to keep any limitation
by the State to a man upon his own freedom and hardship of life other than as procedure
established by law.

In any case, can The privilege to life be translated to such a degree which prompts its self
destruction(right to die) ? This is the significant point where the level headed discussion
emerges.

At the point when a man takes his life by his own particular demonstration we call it suicide
yet to end life of a man by other on the demand of the deceased is called mercy killing or
passive euthanasia. It implies applying such strategies and means which will make the demise
effortless and diminish the individual from hopelessness and agony of life. There are different
sorts of euthanasia which are legitimate in India.

Suicide and killing can't be dealt with as one and same thing. They are two unique acts.

However, in State of Maharashtra V. Maruty Sripati Dubal2 the Court clarified the situation
of Indian law on euthanasia as under:

"Mercy killing is only manslaughter, whatever the conditions in which it is influenced.

Unless it is particularly acknowledged it can't however be an offense. Our penal code
additionally punishes both abetment of murder as well as the abetment of suicide."

1
The Constitution of India
2
AIR 1986 Mah LJ 913

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Literature Review
The question whether right to die is incorporated into Article 21 of the constitution came for
consideration under the watchful eye of the Bombay High Court in State of Maharashtra V.
Maruty Sripati Dubal3. The Bombay High Court held that the right to life ensured by Art. 21
incorporates a right to die and therefore the court struck down Section 309, IPC which
provides punishment for an attempt to commit suicide by a man as constitutional. They held
that everybody has the right to discard his life as and when he wants.

Then again, the Andhra Pradesh High Court in Chenna Jagadeshwar V. Province of A.P. 4
held that the right to die isn't a fundamental right inside the importance of Article 21 and
consequently Section 309, IPC isn't unlawful.

In P. Rathinam V. Association of India5 a division seat of the Supreme Court concurring with
a perspective of the Bombay High Court in Maruti Sripati Dubal case held that a man has a
right to die and pronounced Section 309 of the Indian Penal Code unconstitutional which
makes Attempt to commit suicide a penal offense. A man can't be compelled to appreciate
ideal to life to his burden, weakness or detesting. Clarifying the explanation behind its
judgement the Court said that Section 309, IPC should be destroyed from the Statute Book to
refine our penal laws. It is a remorseless and nonsensical arrangement and may bring about
rebuffing a man again who has endured distress and would experience lowness in light of his
inability to commit suicide.

However , the court dismissed the plea that euthanasia ought to be allowed by law. The
judges said that they would not choose this point as firstly it is past the extent of the present
appeal to and secondly likewise on the grounds that in euthanasia, a third individual is either
effectively or latently included about whom it might be said that he helps or abets the
executing of someone else. There is a ditinction between an endeavor of a man to commit
suicide and to convey to end the life of himself by any other individual

This judgment may have come as an expectation of freedom to some who are in an
exceptionally discouraged and irreversible perspective or body however it neglected to
contemplate its impact on youthful juvenile people which tend to act or respond in frantic
haste. Additionally in the dowry death cases the accused takes the plea that the deceased has
committed suicide while it is generally otherwise. Again suicide attributable to
disappointment in love, disappointment in examinations and inability to land a position or
even a great job or advancements in administration would raise numerous social issues.

3
AIR 1986 Mah LJ 913
4
AIR 1988Cr LJ 549
5
(1994) 3 SCC 394

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In this way, in Gian Kaur V. Province of Punjab6 a five judge Constitutional Bench of the
Supreme Court has overruled the P. Rathinam's case and held that "right to life" under Article
21 does exclude "right to die". Any part of life which makes it honorable might be read into
Article 21 of the Constitution however not what quenches it and is, thus conflicting with the
proceeded with presence of life bringing about destroying the correct itself. Right to life is a
natural right exemplified in Article 21 however suicide is an unnatural end or eradication of
life and incongruent and conflicting with the idea of ideal to life.

The court made it clear that right to die with dignity at the end of life is not to be confused
with the right to die an unnatural death curtailing the natural span of life.

The Court reiterated that the argument to support the views of permitting termination of life
in such cases(dying man who is terminally ill or in a vegetative state) by accelerating the
process of natural death when it was certain and imminent was not available to interpret
Article 21 to include therein the right to curtail the natural span of life.

Gain Kaur, however, appears to have approved passive euthanasia by holding that one may,
in a given case, have “the right to die’ with dignity as a part of ‘right to live’ with dignity”. A
person having death knocking at the door because of his terminal illness or extreme old ages
and where death is imminent and the process of death has already commanded, may deny or
may be denied any further medical aid so that his suffering may not be prolonged, because
these are not cases of extinguishing life but only of accelerating conclusion of the process of
natural death which has already commenced”.

On the subject of euthanasia in Aruna Ramchandra Shanbaugh V. Union of India7 a writ

petition was filed by Ms. Pinki Virani of Mumbai claiming to be next friend of Aruna
Shanbaugh with a prayer for direction to the respondent to stop feeding and let Aruna die
peacefully. Her parents were dead and her close relatives had no interest in her since she had
unfortunate assault on her. Regarding the withdrawal of life support to a person in
PVS(Persistent Vegetative State) or who was otherwise incompetent to take a decision in this
connection, the Supreme Court in a two Judges Bench decision laid down the law of passive
euthanasia8 to continue till the law made by parliament on the subject, as follows:

 A choice must be taken to cease life bolster either by guardians or the mate or other
close relatives, or without any of them, such a choice can be taken by a man or an
assemblage of people going about as next companion. It can likewise be taken by the
specialists going to the patient. However the choice ought to be taken real to the
greatest advantage of the patient.
 Also the approval of Court is needed for decision to withdraw life support as there is
always a risk that the provision may be misused.

6
(1996) 2 SCC 648
7
AIR 2011 SC 1290
8
passive euthanasia-Hastening the death of a person by altering some form of support and letting nature
takes its course.

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Law Commission Report:

It must be remembered that the 17th Law Commission of India then headed by Justice M.
Jagannadha Rao in its 196th Report submitted in April,2006 titled ‘Medical Treatment to
Terminally Ill-patients (Protection of patients and Medical Practitioners)’ had supported and
made recommendations for drafting legislation on the passive euthanasia.

In order to address the debate revolving around ‘Right to Die’, one needs to finally refer to
the case of Cruzan v. Director, Missouri Dept. of Health9, commonly known as the Nancy
Cruzan Case in which the U.S. Supreme Court held that the parents’ request to withdraw
artificial life saving devices can be complied with only if there is a clear and convincing
evidence of the patient’s wish to die. Since there was enough compliance with the clear and
convincing evidence standard in this case, the devices were removed and the patient
peacefully died. However, the Supreme Court only conceded a constitutionally protected
‘liberty interest’ in refusing unwanted medical treatment. The majority was careful not to
suggest that competent parties have a fundamental right to refuse treatment, for if they did so,
the fundamental right would have to be protected unless the State interest was shown to be
compelling.

In recent case Common Cause &ors v. Union of India10, it was held that passive euthnesia is
allowed with voluntary consent of the person.

Statement of Problem:
Though passive euthanasia is legalized in India, there is still need to enact a legislation to
protect the rights of terminally illi patients or patients in permanent vegetative stateii. This
paper will attempt to find the answer to the same.

Methodology:
A Doctrinal Research method has been adopted.

Objectives:
 To analyse the advantages and disadvantages of legalizing euthanasia in India.
 To analyse the situation of euthanasia in other countries with respect to their laws .

9
497 U.S. 261 (1990)
10
2018.

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Hypothesis:
Euthanasia: Inconsistent with the concept of Right to Life.

Research Questions:
 What is euthanasia and its types?
 What is the legal perspective of other countries on euthanasia?
 Whether euthanasia should be legalized in India?

Definition of Euthanasia and its Types.

Definition-Euthanasia is the deliberate production of the death of a human being on the

grounds that in his situation it is considered that it is better that he should be dead than that he
should continue to live11. Several types of euthanasia can and should recognised. These may
be classified on the basis of the presence or absence of the agreement of the subject. Such as-

Voluntary Euthanasia alludes to the move made by the doctor and the patient, who both
concur (with educated assent) to end the patient's life.

Involuntary Euthanasia-refers to a third party taking a patient's life without the informed
consent of the patient. This is usually used in veterinary solution when creatures are "put
down" or "put to rest." In present day pharmaceutical, it could possibly be connected to the
demonstration of taking an in critical condition, enduring patient's life who has lost all
psychological ability to make his/her own particular choices. It is otherwise called doctor
helped suicide or kindness executing

Passive euthanasia-involves withdrawing or withholding life-prolonging medical treatment

with the intention to hasten death in the patient's interests because of their expected negative
quality of life.

Active euthanasia-means a positive merciful act to end useless sufferings and a meaningless
existence. It is an act of commission.

11
Lewy G. Assisted suicide in US and Europe. New York: Oxford University Press, Inc; 2011.

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Non-Voluntary- this is where the person is unable to ask for euthanasia (perhaps they are
unconscious or otherwise unable to communicate), or to make a meaningful choice between
living and dying and an appropriate person takes the decision on their behalf, perhaps in
accordance with their living will, or previously expressed wishes. Situations in which the
person cannot make a decision or cannot make their wishes known, includes cases where:

 The person is in a coma.

 The person is too young (e.g. a very young baby).
 The person is senile.
 The person is mentally retarded to a very severe extent.
 The person is severely brain damaged.
 The person is mentally disturbed in such a way that they should be protected from
themselves.

Voluntary death from the historical and philosophical and

religious perspective.

Hinduism and Buddhism allow "prayopaveshan" since it is a non violent, calm and much
time taking way of ending life and it occurs by starving oneself to death at the right time.
Prayopaveshan is for people who are satisfied with their lives. While on the other hand,
suicide is a sudden act and associated with the feelings of anger, frustration, depression which
is why it is not allowed by any of these religions. In spite of the fact that there is a division of
perspectives with respect to euthanasia in Buddhism, the most well-known view is that
euthanasia ought not be allowed. Again there are two perspectives of Hinduism with respect
to euthanasia which are opposing, one is supporting killing as an ethical deed and another is
thinking about killing as an awful deed which exasperates the life and demise cycle.
Old Indian philosophical custom additionally legitimizes the possibility of a man willing his
own particular demise. According to Hindu folklore Lord Rama and his siblings took 'jal
samadhi' in River Saryu close to Ayodhya. Old Indian history likewise tells that Lord Buddha
and Lord Mahavir attained death by seeking it..
Jainism gives full consent to its followers who want to embrace death mostly by fasting, if
they believe that ‘moksha’ can be achieved that way.
Muslim, Christian and Jewish laws are all against suicide and even willful extermination. As
indicated by these religions , all human life is hallowed since it is given by God, and people
ought not meddle in this.
The Roman Catholic Church regards euthanasia as morally wrong since it has always taught
how important the commandment ‘you shall not kill’ is.
The idea of willful death is traceable to Socrates, Plato, and Stoics in ancient Greek and
Roman philosophy as well. In ancient Greece and Rome, helping others to put end to their
lives was also permitted in certain situations.

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Position Of Euthanasia in other Countries.

In the case of Euthanasia and Assisted Suicide, the countries that advocate 'mercy killing' are
Holland, Northern Provinces of Australia as well as some states in the United States of
America. The Netherlands is the first country in the world to legalize euthanasia. The bill
allows doctors to kill patients with terminal diseases who are suffering "unbearably," if they
request it.

In Netherland
On 18 April, 2001, the first nation in the world to legalize euthanasia, often called mercy
killing. The Dutch decision to allow doctors to kill patients who are undergoing unbearable
suffering from terminal illnesses gave rise to angry protests from the pro-life lobby across the
world. But the move was also welcomed by several human rights activists and patients
organizations who said that a long-accepted practice in the Netherlands had finally been
given legal sanction. Doctors in Holland regularly perform mercy killing in consultation with
patients and their families.

In Australia
Assisted suicide was legal in Australia for a period, but now is not. In 1995, the world's first
euthanasia legislation, the Rights of the Terminally ill Act 1995, was passed in the Northern
Territory of Australia. Four patients died under the Act, using a euthanasia device designed
by Dr. Philip Nitschke. The legislation was overturned by Australia's Federal Parliament in
1997. In response to the overturning of the Act, Dr. Nitschke founded Exit Internationaliii.

In France
The controversy over legalizing euthanasia and physician assisted suicide is not as big as in
the United States because of the country's "'well developed hospice care program." However,
in 2000 the controversy over the uncontroversial topic was ignited with Vincent Humbert.
After a car crash that left him "unable to 'walk, see, speak, smell or taste'", he used the
movement of his right thumb to write a book, I Ask the Right to Die in which he voiced his
desire to "die legally." After his appeal was denied, his mother assisted in killing him by
injecting him with an overdose of barbiturates that put him into a coma, killing him 2 days
later. Though his mother was arrested for aiding in her son's death and later acquitted, the
case did jumpstart a new legislation which states that "when medicine serves no other
purpose than the artificial support of life they can be suspended or not undertaken."

In Colombia

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Despite its strict Roman Catholic history, in May 1997 Colombian courts allowed for the
euthanasia of sick patients who requested to end their lives. This ruling came about due to the
efforts of a group that strongly opposed euthanasia. When one of their members brought a
lawsuit to the Colombian Supreme Court against it, the court issued a 6 to 3 decision that
spelled out the rights of a terminally person to engage in voluntary euthanasia.

In USA
U.S. laws prohibit active euthanasia. But the courts ruled that passive euthanasia is legalized
as it says that doctors should not be punished if they withhold or withdraw a life-sustaining
treatment at the request of patient. In 1991 Federal Patient Self-Determination Act, was made
effective which required federally certified health-care facilities to notify adult patients of
their rights to accept or refuse the medical treatment. The facilities should also inform the
patients of their rights under the state laws to formulate advanced directives.

In Canada
Patients have the similar rights as in case of U.S. to refuse life-sustaining treatment and
formulate advanced directives. However, they do not possess right to active euthanasia or
assisted suicide.

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Arguments in favour of Legalizing Euthanasia.

Euthanasia is a way of ending a person’s life who has been suffering from intolerable pain or
undignified death. Various countries have legalized it. The debate regarding euthanasia has
going on from very long time but only recently euthanasia gained massive importance. After
the landmark judgment passed by the Indian Court in Aruna’s case it’s clear that passive
euthanasia is now allowed in India. But still there is some ambiguity with regard to
euthanasia. The various arguments for legalizing euthanasia given by supporters of
euthanasia are-

Moral Objectives: It is morally incorrect to keep a person fighting for no cause when all
hope is lost. The sufferer and his fraternity go through mental trauma for a long period of
time. The society is obligated to acknowledge the rights of patients and to respect the
decisions of those who elect euthanasia. Every individual’s right to self-determination or his
right of privacy needs to be respected. Interference to such rights can be justified if it is to
protect values, which is not the case where patients suffering unbearably at the end of their
lives request euthanasia leaving them with no alternatives. People can’t suffer against their
will. It is plain cruelty on them and cessation of their human rights and dignity.

Individual’s right to exercise his choice: Firstly deciding if one wants to live or die is a
personal decision. Every individual has his/her own rights over their body. When the birth of
an individual is not questioned by anyone naturally death as well should not be a speculative
debate. A painless death is better than a painful life. The increase in patients of Cancer, AIDS
and other dreadful and irreparable diseases has sparked a world-wide need of euthanasia or
mercy killing. Especially in the final stages of such diseases which are incurable the want of
euthanasia is justified.

Economic Factor: Economic concern in a country like India is of primary importance. The
medical charges are unaffordable for the needed medical care; unsure if the patient is going to
improve in any possible way or remain as he is. And every irreparable disease attracts a big
amount of risk and money which can’t be ignored. Moreover, there is increasing pressure on
hospital and medical facilities; it is argued that the same facilities should be used for the
benefit of other patients who have a better chance of recovery and to whom these facilities

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provided by the hospital would be of greater value. Thus, the argument runs, when one has to
choose between a patient beyond recovery and one who may be saved, the latter should be
preferred as the former will die in any case.

Refusing care: Right to refuse medical treatment is well recognised in law, including
medical treatment that sustains or prolongs life. For example, a patient suffering from blood
cancer can refuse treatment or deny feeds through medical tube. Recognition of right to
refuse treatment gives a way for passive euthanasia. Many do argue that allowing medical
termination of pregnancy before 16 week is also a form of active involuntary euthanasia. This
issue of mercy killing of deformed babies has already been in discussion in Holland.12

Right to die: Many patients in a persistent vegetative state or else in chronic illness, do not
want to be a burden on their family members. Euthanasia can be considered as a way to
upheld the ‘Right to life’ by honouring ‘Right to die’ with dignity.

Encouraging the organ transplantation: Euthanasia in terminally ill patients provides an

opportunity to advocate for organ donation. This in turn will help many patients with organ
failure waiting for transplantation. Not only euthanasia gives Right to die for the terminally
ill, but also Right to life for the organ needy patients.

It is evident from the court’s ruling in the recent case of K. Venkatesh , a twenty-five year old
boy suffering from muscular dystrophy, who was aware of his incurable predicament and
hence, wanted to donate his organs to someone needy before he could die. The Andhra
Pradesh High Court however, turned down the humanitarian appeal of an ailing man on
deathbed.

12
Sheldon T. Dutch legal protection scheme for doctors involved in mercy killing of babies receives first report.
BMJ.

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Arguments against Legalizing Euthanasia.

Research has revealed that many terminally ill patients requesting euthanasia, have major
depression, and that the desire for death in terminal patients is correlated with the
depression13. They need palliative and rehabilitative care. Palliative care actually provides
death with dignity and a death considered good by the patient and the care givers. The
various arguments given by the people against euthanasia are-

Eliminating the invalid: Euthanasia opposers argue that if we embrace ‘the right to death
with dignity’, people with incurable and debilitating illnesses will be disposed from our
civilised society. The practice of palliative care counters this view, as palliative care would
provide relief from distressing symptoms and pain, and support to the patient as well as the
care giver. Palliative care is an active, compassionate and creative care for the dying.

Constitution of India: ‘Right to life’ is a natural right embodied in Article 21 but suicide is
an unnatural termination or extinction of life and, therefore, incompatible and inconsistent
with the concept of ‘right to life’. It is the duty of the State to protect life and the physician's
duty to provide care and not to harm patients. If euthanasia is legalised, then there is a grave
apprehension that the State may refuse to invest in health (working towards Right to life).
Legalised euthanasia has led to a severe decline in the quality of care for terminally-ill
patients in Holland. Hence, in a welfare state there should not be any role of euthanasia in
any form.

Symptom of mental illness: Attempts to suicide or completed suicide are commonly seen in
patients suffering from depression, schizophrenia and substance users. It is also documented
in patients suffering from obsessive compulsive disorder. Hence, it is essential to assess the
mental status of the individual seeking for euthanasia. In classical teaching, attempt to suicide
is a psychiatric emergency and it is considered as a desperate call for help or assistance.
Several guidelines have been formulated for management of suicidal patients in psychiatry.
Hence, attempted suicide is considered as a sign of mental illness.

Malafide intention: In the era of declining morality and justice, there is a possibility of
misusing euthanasia by family members or relatives for inheriting the property of the patient.
Hence, to keep control over the medical professionals, the Indian Medical Council
(Professional Conduct, Etiquette and Ethics) Regulations, 2002 discusses euthanasia briefly
and it is in accordance with the provisions of the Transplantation of Human Organ Act, 1994.
There is an urgent need to protect patients and also medical practitioners caring the terminally
ill patients from unnecessary lawsuit. Law commission had submitted a report to the
government on this issue.

13
Chochinov HM, Wilson KG, Enns M. Desire for death in the terminally ill. Am J Psychiatry. 1995

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Commercialisation of health care: Passive euthanasia occurs in majority of the hospitals

across the county, where poor patients and their family members refuse or withdraw
treatment because of the huge cost involved in keeping them alive. If euthanasia is legalised,
then commercial health sector will serve death sentence to many disabled and elderly citizens
of India for meagre amount of money14.

CONCLUSION
Although legalizing euthanasia will end the suffering and pain of patients and their family but
termination of life is not an answer to pain so right to die should remain generally illegal but
there should be an exception granted to people who are terminally ill and in excruciating pain
because of that (like L. Venkatesh).

But doctors often disagree on what defines terminal illness. And while there will certainly be
some cases where death is inevitable, there will be many cases where death is fairly far off in
the future, and there is some hope, however small. As medical experts have acknowledged
that it is virtually impossible to predict the life expectancy of a particular individual and the
term "terminally ill" has no precise definition though Jack Kervorkian, a famous proponent of
euthanasia, defined terminal illness as "any disease that curtails life even for a day". Some
laws define terminal as one from which death will occur in a relatively short time or within a
span of six months.

This is the situation till now and seems to remain the same in near future, and the suffering of
people like Venkatesh is unfortunate. On the other hand, if in future It could be convinced
that doctors could specify the cases where euthanasia is the best option with upwards of 99%
certainty (this would require a classification of terminal illnesses and ascertainment of
survivability, then may be legalizing euthanasia would also serve the common good.

Though the legalization of euthanasia in India seems to be a distant dream as most of the
patients succumb to death without receiving any primary health care. India does not have an
appropriate health-care mechanism in place, let alone lay down procedures for euthanasia. If
the State takes the responsibility of providing reasonable degree of health care, then majority
of the euthanasia supporters will definitely reconsider their argument15.

14
Gursahani R. Life and death after Aruna Shanbaug. Indian J Med Ethics.2011;8:68–9.
15
Law Commission report no.196 on medical treatment to terminally ill patients.

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BIBLIOGRAPHY

Books Referred:
 A.M. Bhattacharjee, Equality, Liberty and Property under the Indian Constitution
(Calcutta: Eastern Law House, 1997)
 The Constitution Of India, 3rd Edition, Eastern Law Company, Lucknow
 Dr. J.N. Pandey, The Constitutional Law Of India, 49th Ed., Cental Law Agency, 2012
 Black Law Dictionary, 9th Edition

Statutes Referred:
 The Indian Penal Code,1860
 The Indian Medical Council (Professional Conduct, Etiquette and Ethics)
Regulations, 2002
 The Transplantation of Human Organ Act, 1994

Articles Referred:
 A.M. Bhattacharjee, Article 21 and the Due Process and the Exclusionary Rule of
Evidence (1983) 3 SCC (J). (accessed on October 2, 2013)
 B.B. Pande, Right to Life or Death ? For Bharat both cannot be Right (1994) 4 SCC
(J). (accessed on October 2, 2013)
 Rajeev Dhavan, “The Right to Die”, The Hindu ( accessed on October 2, 2013).
 Sheeraz Latif Ali Khan, ” Right to Die or not to Die : A Note on the Supreme Court
Judgement” (1993) 1 SCJ (J.S.). (accessed on October 2, 2013)
 Law Commission report no.196 on medical treatment to terminally ill patients.
(accessed on August 12, 2013).
from:http://lawcommissionofindia.nie.in/reports/rep196.pdf .

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i
Terminal illness is a medical term popularized in the 20th century to describe a disease that
cannot be cured or adequately treated and that is reasonably expected to result in
the death ofthe patient within a short period of time. This term is more commonly used for
progressive diseases such as cancer or advanced heart disease than for trauma. In popular use,
it indicates a disease which will eventually end the life of the sufferer.

ii A persistent vegetative state is a disorder of consciousness in which patients with

severe brain damage are in a state of partial arousal rather than true awareness. It is a
diagnosis of some uncertainty in that it deals with a syndrome. After four weeks in
a vegetative state (VS), the patient is classified as in a persistent vegetative state.
iii
Exit International, is an international non-profit organization advocating legalization
of euthanasia. It was previously known as the Voluntary Euthanasia Research
Foundation (VERF Inc.)

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