Explainer
How does the assisted dying bill in England and Wales compare to the Isle of Man?
Assisted dying proposals are progressing through the legislative process both in England and Wales, and in the Isle of Man.
While both bills intend to give the right for those with terminal illnesses to end their own life, both proposals differ in detail.
In England and Wales, an individual must have less than six months to live, whereas in the Isle of Man, the choice to end their own life extends to those with less than 12 months to live.
On the island, anyone wishing to have an assisted death must have lived there for at least five years, whereas in England and Wales, that number shrinks to just 12 months.
While the Isle of Man has been debating assisted dying for more than two years, politicians on both sides of the water are still debating draft proposals, which are subject to change.
However, the publication of the bill in England and Wales gives the first indication on how proposals may differ, if both eventually become law.
England and Wales
The 'Terminally Ill Adults (End of Life) Bill' would apply specifically to those in England and Wales, and was brought to Westminster by Labour MP Kim Leadbeater.
Under the draft bill, there are certain requirements for someone to be eligible for assisted dying:
They must be 18 or older.
They must be a resident in England and Wales, and registered with a GP for 12 months or more.
They must have a terminal illness, with less that six months to live.
They must have the mental capacity to make the choice about ending their life.
They must be able to self-administer the medication.
They must make two separate declarations, both witnesses and signed, about their wish to die.
Two independent doctors must be satisfied that the person is eligible, but doctors have no obligation to take part.
A High Court judge must hear from at least one of the doctors regarding the application.
There must be at least seven days between two doctors making their assessments, and a further 14 days after the judge makes any ruling, before any action can take place.
Those whose death is expected imminently can apply to reduce the 14-day period to 48 hours.
The bill includes safeguards to prevent pressure or coercion, and those found guilty of such actions could face up to 14 years in jail.
Ms Leadbeater has suggested a new law would not take effect for another two to three years, with “even more consultation to make sure we get it right” once legislation was passed.
Isle of Man
In the Isle of Man, the assisted dying debate has been progressing through parliament since Dr Alex Allinson brought the private members bill to Tynwald in 2022.
In July 2024, the bill passed through the House of Keys, and is now facing further scrutiny in the Legislative Council.
Politicians voted seven to one to pass the bill through the Principles stage - the initial debate in the upper chamber of Tynwald.
The draft Isle of Man bill also lays out specific requirements for those wanting an assisted death:
They must be 18 or older.
They must have a terminal illness, with less that 12 months to live.
They must have lived on the Isle of Man for over five years.
They must have the mental capacity to make the choice about ending their life.
They must be able to self-administer the medication.
The bill includes safeguards to prevent pressure or coercion, and those found guilty of such actions could face up to 14 years in jail.
Posting on X, Dr Allinson said: "Very useful to read the Bill published yesterday which has many of the same safeguards and provisions for choice and dignity for those with a terminal diagnosis as the Isle of Man legislation.
"I hope MPs will represent the views of their constituents on this important issue."
If Dr Allinson's Bill continues its trajectory, it could receive Royal Assent as soon as 2025, with assisted dying potentially available to terminally ill residents from 2027.
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