World Watching, But No Consensus on Ethics of Death

LONDON -- While U.S. politicians and courts debated the implications of removing Terri Schiavo’s feeding tube, the rest of the world looked on this week with a mixture of revulsion and approval.

Many commentators disagreed with the intervention of President Bush and Congress in the case of the brain-damaged 41-year-old, saying such vital, complex decisions are best left to courts, physicians and the family. They accused Bush and his religious-right allies of hypocrisy and political posturing.

Other commentators gave plaudits to Bush -- or at least welcomed the attention on Schiavo, saying it had revived much-needed public debate on when and how to prolong life in apparently hopeless cases.

“American moral melodramas quite often prove to be soap operas, but at least serve some useful purpose in focusing public attention on important issues that might otherwise be ignored,” Australia’s Canberra Times said about the Schiavo case.

Across the globe, there is no consensus on a patient’s right to die. Many developing nations simply don’t have the medical resources to keep coma patients alive indefinitely, nor the expectation that anyone would do so.

In Western Europe and in Australia and other developed countries, however, the question of when to allow patients to die has been argued for decades. Several countries have adjudicated cases broadly similar to Schiavo’s, and European courts in recent years have tended to allow life support to end if physicians and a competent patient or guardian agree the case is hopeless.

Belgium and the Netherlands are the most radical. Both countries allow doctors to commit euthanasia, or mercy killing, of patients who state that wish and who are deemed to be suffering unbearably with little or no hope of recovery. Other European countries have backed away from that, fearing the authorization could be abused.

“I do make a distinction between giving a lethal injection and withdrawing treatment,” said Dr. Piers Benn, a lecturer in medical ethics at London’s Imperial College.

The Schiavo case is additionally troubling because the patient, although in what doctors say is a persistent vegetative state, is not otherwise in a crisis, he said.

“If there is a proper diagnosis of persistent vegetative state, and if there is no prospect of any conscious life, and there is another [medical] crisis, then I think it would be legitimate not to resuscitate,” Benn said. Absent a crisis, he said, he is not sure.

Polly Toynbee, a writer for Britain’s left-leaning Guardian newspaper, cited the drawn-out, “unkindly” death of her own ill mother in a column Friday arguing that doctors should be allowed to induce death.

Toynbee complained that the “religious lobby forces people to die in pain and indignity due to beliefs on the nature of life and death shared by very few.”

In Switzerland, doctors may supply lethal drugs to a patient who wishes to commit suicide, but they may not administer them.

In Britain, the courts have allowed a sort of loophole, saying doctors may give potentially lethal doses of drugs to terminal patients if the aim is to relieve pain, not to deliberately bring about death. No one knows how many British patients have died in this way.

Israel had been weighing the right-to-die issue in recent months, even before the Schiavo case came to prominence.

In February, the Knesset gave initial approval to a bill permitting, for the first time in the country’s history, passive euthanasia for terminally ill patients who had requested it.

The parliamentary measure moved forward on the recommendation of a two-year study by experts led by Avraham Steinberg, a neurologist and a leading international authority on Jewish medical ethics. Steinberg, a practicing Orthodox Jew, found what he described as ample basis in Jewish law, or Halakha, for ending the suffering of patients whose cases were considered hopeless.

China, too, has weighed the issue in recent years. But Zhou Xiaozheng, a sociologist at People’s University in Beijing, said he didn’t expect China to legalize euthanasia anytime soon, owing to widespread corruption.

“If it were allowed here, it could be subject to abuse by people who want to get rid of someone they don’t like,” he said.

Any kind of active euthanasia is banned in Germany and is punished as murder, manslaughter or denial of assistance, depending on circumstances. A physician isn’t allowed to assist a suicide even if it is the declared will of a patient.

The strict laws are a reaction to the Nazi era, when thousands of disabled people were labeled “unworthy to live” and killed. But activist groups have been lobbying for a clear law to permit patients to state their preferences for treatment in living wills.

This pressure has increased because of Schiavo’s case, which has dominated German newspapers’ front pages. The main political parties are drafting joint legislation expected to go before parliament this fall, which would let people with terminal diseases decide in advance how they want to be treated.

Bush’s intervention, meanwhile, has won some respect in Germany. The centrist Berlin newspaper Tagesspiegel said the president’s actions made moral sense.

“A person is going to starve to death who is neither suffering from a deadly disease nor has left a living will,” the newspaper said in an editorial Tuesday. “That may be in accord with the laws in Florida, but then these laws are simply wrong.

In November, French lawmakers passed a right-to-die law in the wake of a highly publicized case of a 22-year-old man, partially blinded and paralyzed in an automobile accident, whom his physician and his mother helped to die.

Marie Humbert had appealed for help to President Jacques Chirac before she administered the massive dose of barbiturates to her son Vincent in September 2003. She and the physician, Frederic Chaussoy, remain under criminal investigation.

“Vincent is dead,” Chaussoy, 52, wrote in a recent book about the case. “That’s what he wanted. I just helped him leave his prison. I just hope this won’t send me into one for the rest of my life.”

In Roman Catholic Italy, the Schiavo case is under scrutiny. The Vatican and several Italian politicians have condemned the decision to remove Schiavo’s feeding tube and have praised Bush and his brother, Jeb Bush, the Florida governor.

The Vatican does not usually comment on specific legal cases but made an exception for Schiavo. L’Osservatore Romano said in a front-page editorial that she had been condemned to “an atrocious death.”

“Who can decide to pull the plug, as if we were talking about a broken or out-of-order household appliance?” the paper said.

“Who can, before God and humanity, pretend with impunity to claim such a right?”

Catholic teaching does not require extraordinary measures to artificially extend the life of a critically ill patient, especially if there doesn’t seem to be a reasonable chance of recovery. But Pope John Paul II has said there is a moral obligation to provide water and nourishment to a vegetative patient.

Italian Health Minister Girolamo Sirchia branded the decision made by Schiavo’s husband, Michael, to remove the feeding tube “a horrible shortcut camouflaged as an act of love.” And he said laws to loosen restrictions on euthanasia, such as in the Netherlands, were “very dangerous” because the practice of assisted death could get out of hand.

Italy’s minister for European affairs, Rocco Buttiglione, echoed the Vatican in branding as murder the removal of Schiavo’s feeding tube.

When an Italian magazine asked Buttiglione what he would wish if he were in an irreversible coma, he replied: “I could only pray to God to take my life. I would never ask my children to kill me.”

Times staff writers Robyn Dixon in Johannesburg, Laura King in Jerusalem, Ching-Ching Ni in Beijing, Richard C. Paddock in Jakarta, Achrene Sicakyuz in Paris, Janet Stobart in London, Tracy Wilkinson in Rome and Christian Retzlaff in Berlin contributed to this report.