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
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
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.
Four years earlier, however, a court had ruled in favor of a
woman trying to stop doctors removing life support from her brother,
who was in a heroin-induced coma.
Recent guidelines advising New South Wales doctors on end-of-
life care are designed to minimize conflicts with family members,
but "they don't explain the key principle of what is appropriate and
what is not appropriate" medical treatment, worries Bernadette
Tobin, director of Sydney's Plunkett Center for Ethics. …