World divided on ethics of Terri Schiavo case

Every country in the world with the technology - and willingness - to keep such patients alive has had its Terri Schiavo. Almost every one has dealt differently with the dilemmas the drama raised.

From the Netherlands, where euthanasia and assisted suicides are legal and common, to India, where no doctor is allowed to deny lifesaving treatment to any patient, no matter how hopeless, governments are struggling to draft ethical and practical laws governing so-called mercy killing.

In the meantime, say doctors and activists on both sides of the debate, doctors are turning off thousands of life-support machines every day behind curtains of ambiguity and confusion, lacking clear legal guidelines.

Even in Europe, where debate has led to more legislation than anywhere else, "active euthanasia ... is regularly practiced even in countries where it is prohibited," a recent Council of Europe report found. "Criminal convictions and administrative and professional sanc- tions are, on the other hand, extremely rare."

For most people in the world, living in poor countries with few sophisticated life-support machines, the debate swirling in the United States around Ms. Schiavo's case is almost unimaginable.

The dilemma facing Schiavo's family members "is not a major issue at all" for Indians, says Roopinder Singh, a commentator for The Tribune newspaper in Chandigargh. The huge costs involved in keeping someone alive for 15 years would be "killing for the family," he adds.

Similarly, at the world's largest hospital, in the black South African township of Soweto, AIDS is a much more pressing problem. Nearly 2,000 people - half of them HIV positive - check into Chris Hani-Baragwanath each day.

"A lot of resources would be going to maintain" a patient like Schiavo, "and you might say they could be used elsewhere," explains Natalya Dinat, a specialist at the sprawling complex. Philosophical debates about life and death are a luxury, she says, and "you only have these luxuries where death is a rare thing."

But traditional African values, which emphasize family and community needs over individual rights, color attitudes as much as the shortage of money.

Once, argues Stella Mhango of the Khara Heritage Institute in Pretoria, that would mean "the whole community would come together" to try to save someone like Schiavo. Today, suggests Dr. Dinat, that communal ethic, and AIDS patients' fear of becoming a burden, could explain the recent 15-fold increase in suicides in South Africa.

For many outside the US, the very public twists and turns of Schiavo's case through the courts and Congress are hard to fathom.

Brazilians, for example, who rarely resolve their problems through the judiciary, tend not to feel that such personal issues are a matter for courts to decide.

"This is a question for the family," says Irene Henriquez, a Sao Paulo housewife. Nor can courts intervene in such cases in France, where "our logic is less judicial than in the English-speaking world," says Xavier Mirabel, who heads the Association for the Right to Life, based in Paris.

Cases like Schiavo's do not often come before the courts in Australia either. Most patients' relatives accept a doctor's decision that further treatment is pointless. But when judges have become involved, they have sent contradictory signals.

Last year, doctors at St. George's Hospital in Sydney decided to switch off the life-support system of a 75-year-old man in a coma. His distraught relatives took the matter to the New South Wales Supreme Court, which upheld the doctors' view.

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