World divided on ethics of Terri Schiavo case

The law has been welcomed, with some reservations, by activists on both sides of the euthanasia debate, though it is ambiguous about doctors' right to give potentially fatal doses of painkillers. High doses are permitted to ease discomfort even if the doctor suspects they might kill the patient as a secondary effect, but not if they are intentionally deadly.

Stopping short of legalizing euthanasia, the law "does not go far enough," says Danielle Metro, an official at the Association for the Right to Die in Dignity, based in Paris, "but it does protect doctors better" against lawsuits by outraged relatives.

"Doctors have a duty to switch off machines in some circumstances; it would be ethically scandalous to impose them," says Dr. Mirabel, a devout Roman Catholic, who runs a website advising families on end-of-life issues. "If they couldn't turn them off, we would all die hooked up to a bank of machines, and that is not dignified."

Mirabel is unhappy, however, that the French law specifies feeding tubes as the sort of treatment that can legally be withdrawn. "Respirators can honestly be seen as unreasonable treatment, but feeding is not the same," he argues.

That is the view espoused in Spanish legislation passed three years ago, under which Schiavo's doctors would not be allowed to stop feeding her artificially unless she had personally left written instructions to the contrary.

The Spanish law resulted from the drama surrounding Ramon Sampedro, paralyzed from the neck down by an accident, whose story was told in the film "The Sea Inside," which won an Oscar last month for Best Foreign Film.

He pleaded for someone to be allowed to help him die, and eventually found someone who agreed to administer a fatal dose of potassium cyanide.

Such an act would still be illegal in Spain, but the law does allow doctors to "limit, suspend, or not initiate treatment" in certain circumstances, even if doing so will cause the patient's death.

Spanish public opinion is strongly in favor of legalizing euthanasia, as are 60 percent of Spanish doctors, an unusually high proportion.

"The fundamental problem is that the medical professions are not united on this," says Derek Humphry, a lifelong campaigner for euthanasia and assisted suicide, whose bestselling book, "Final Exit," explains methods of suicide.

"The only reason there is sensible legislation in the Netherlands and Belgium is because the medical profession has been supportive," he adds.

In Belgium, euthanasia has been legal since 2002, as it has been in the Netherlands, along with physician-assisted suicide. The two countries report about 2,500 cases a year. In Switzerland, assisted suicide has not been a crime since 1946.

Opinion polls in Europe suggest that some 80 percent of voters would approve such legislation in their countries. The Catholic church, however, remains strongly opposed to the idea, though some bishops have condoned the suspension of aggressive treatment and the administration of potentially fatal painkillers in the interest of relieving a patient's suffering.

"In the end," says. Mirabel, "aggressive therapy and euthanasia both have the same intention. They stem from a desire to master the end of life, and a refusal to accept something that is beyond us."

• Contributors: Dan Murphy in Cairo, Mark Rice-Oxley in London; Lisa Abend in Madrid; Abraham McLaughlin in Johannesburg, South Africa; Janaki Kremmer in Sydney, Australia; Andrew Downie in Sao Paulo, Brazil; Vir Singh in New Delhi; and Fred Weir in Moscow.

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