# introduction

This paper investigates when it is morally permissible for a healthcare professional to provide Medical Assistance in Dying (MAiD) in Canada. While MAiD is legally permitted under defined statutory conditions, the legality of an act does not establish that it is morally permissible. The ethical question at the heart of this paper is under what conditions are healthcare professionals morally permitted to provide MAiD. This is particularly relevant for Canada, where the Supreme Court of Canada (the Court) envisaged MAiD as a carefully monitored exception to the criminal prohibitions on assisted dying, permitted only in clearly defined circumstances with stringent safeguards (1). In reality, however, the legal eligibility criteria are sufficiently broad and subject to such discretionary interpretation that nearly any autonomous patient with a serious illness, disease, or disability may qualify for MAiD, particularly if they are assessed by a healthcare professional predisposed to endorsing requests on the basis of respect for patient autonomy (2).

It is important to clarify that most MAiD procedures in Canada involve patients living with serious, chronic, or terminal conditions, such as cancer, neurodegenerative disorders, or advanced cardiovascular disease (3). Many of the healthcare professionals involved with these patients see their role as one of compassion, ethical responsibility, and responsiveness to patient suffering (4). This paper does not claim that MAiD is routinely provided inappropriately or that those receiving it are ineligible. The concern is not with individual decisions but with the legal structure itself, which requires healthcare professionals to exercise normative discretion while presenting those decisions as if they are purely legal or procedural. In doing so, the law conceals the ethical nature of these judgments, allowing them to proceed without explicit ethical justification. In the absence of a principled ethical framework, legal compliance cannot ensure that decisions to provide MAiD meet the ethical standard of moral permissibility.

To address this gap, this paper develops an ethics framework grounded in the fiduciary duties that structure the healthcare professional–patient relationship. These duties arise from the patient’s vulnerability and the discretionary authority exercised by healthcare professionals. They require that discretionary decisions be guided by obligations of trust, loyalty, and the patient’s best interests, not merely by legal permissibility. Although fiduciary duties remain part of the common law, they are not meaningfully engaged by the legal framework governing MAiD, which is situated within the criminal law. Because MAiD is structured as an exception to the prohibitions on culpable homicide and assisted suicide, legal compliance protects healthcare professionals from prosecution but does not require that fiduciary duties be fulfilled. The presumption of innocence and the burden of proof beyond a reasonable doubt further limit the ability of the legal system to evaluate whether a discretionary decision to provide MAiD was ethically permissible. In practice, a healthcare professional who can demonstrate compliance with the procedural requirements for MAiD (including the eligibility criteria and safeguards) may be able to establish reasonable doubt, even if those requirements were met through highly permissive interpretations or in a manner that is ethically questionable. As a result, decisions that satisfy legal criteria may still fall short of the ethical standards expected from healthcare professionals.

This paper proceeds in three parts. First, it demonstrates that legal eligibility for the provision of MAiD does not logically entail moral permissibility. Second, it argues that MAiD constitutes a legal privilege rather than a claim right, rendering the decision to provide it a matter of discretionary judgment. Third, it develops an ethics framework grounded in the four principles of healthcare ethics: respect for autonomy, beneficence, nonmaleficence, and justice. This framework is not a supplement to legal compliance but a necessary condition for determining when the provision of MAiD is morally permissible. Without such a framework, the provision of MAiD risks being reduced to a procedural affirmation of patient autonomy rather than a substantive ethical decision.
# Definitions and Legal Context

MAiD refers to an intervention where a medical or nurse practitioner (healthcare professional) either administers a lethal substance to a patient upon their request to cause the patient’s death or prescribes the substance for the patient to self-administer to cause their own death (5). These practices have historically been referred to as “voluntary euthanasia” and “assisted suicide.” (6-9) However, this terminology is contentious. Some critics argue that the anacronym MAiD sanitizes and obscures the nature of the act of killing, while proponents contend that it more accurately captures the medical and compassionate context in which the practice occurs (10). The term MAiD was introduced into federal legislation with the passage of Bill C-14 in 2016, but its origin lies in the earlier legislative process in Quebec, which deliberately sought to frame assisted dying as another end-of-life medical procedure rather than as an exception to criminal law.

Quebec began exploring assisted dying in 2009, when the Collège des médecins du Québec released a discussion paper suggesting that physician-assisted death could be considered part of appropriate end-of-life care (11). This led to the creation of the Select Committee on Dying with Dignity, which in 2012 recommended that “medical aid in dying” be legally recognized as another end-of-life option, alongside existing practices such as withdrawal of treatment, palliative care, and continuous palliative sedation (12). In 2014, the Quebec National Assembly enacted Bill 52, *An Act Respecting End-of-Life Care*, which established a legal regime for “medical aid in dying” within the provincial healthcare system (13). This legislation framed assisted dying as a matter of healthcare provision under provincial jurisdiction and did not rely on federal criminal law exemptions.

Importantly, the term “medical aid in dying” was introduced to replace “euthanasia” and “assisted suicide,” which the Select Committee found to be emotionally charged and poorly suited to the legislative goals. The choice of terminology was deliberately euphemistic (14). By framing the intervention as a form of medical care, the Quebec framework situated MAiD within a model of clinical decision-making, thereby distancing it from its roots in criminal law. This terminology was later adopted at the federal level, though within a distinct legal structure that treats MAiD as an exception to criminal prohibitions rather than as a healthcare service.

While Quebec was implementing its legislation, the Supreme Court was adjudicating *Carter v Canada* (2015), which held that the blanket prohibition on assisted dying violated section 7 of the *Canadian Charter of Rights and Freedoms* (the Charter). The Court found that competent adults suffering intolerably from a grievous and irremediable condition should have the option of seeking assistance in dying, provided the request was voluntary and informed. In response, Parliament enacted Bill C-14 in 2016 (amended by Bill C-7 in 2021), which created an exemption from the Criminal Code provisions on culpable homicide, consenting to death, and assisted suicide (15-17). This federal legislation established a distinct criminal law framework for MAiD, grounded in the constitutional division of powers, where criminal law remains a federal responsibility and healthcare a matter of provincial jurisdiction.

## Law and Ethics in the MAiD Legislation

Although MAiD emerged from distinct federal and provincial legislative processes, both frameworks share a common feature, namely, that they establish the conditions under which MAiD is legally permitted. However, while the law defines when the provision of MAiD is legal, it does not determine whether it is morally permissible for a healthcare professional to provide it. This distinction is important, because the legal framework prescribes eligibility and procedural safeguards but does not address the ethical responsibilities of those who perform the procedure. To assess these responsibilities, it is necessary to distinguish law from ethics.

Law and ethics are conceptually distinct domains. Law refers to rules and standards established through governmental processes, such as legislation, regulation, or judicial rulings. These rules carry legal authority and are enforceable through courts, regulators, and law enforcement. In Canada, federal laws are enacted through a formal legislative process that includes the introduction of a bill, debate and revision in both the House of Commons and the Senate, and final approval through Royal Assent (18). These processes produce legally binding legislation.

Ethics, by contrast, is concerned with what individuals and institutions ought to do, based on normative reasoning. Ethical principles are not enacted by vote, nor are they enforced by courts, or law enforcement. Rather, they are grounded in values such as respect for persons, beneficence, nonmaleficence, and justice, and are justified through argument, reflection, and deliberation (19,20). Whereas legal reasoning determines what is permitted or prohibited within a legal system, ethical reasoning evaluates the ethical probity of actions regardless of their legal status. In some cases, law and ethics may align, but this alignment is neither automatic nor guaranteed. A law may prohibit actions that are morally required or permit actions that are morally prohibited. For example, the forced attendance of Indigenous children in residential schools was legally required but constituted a fundamental violation of morality (21). The legality of an action, therefore, cannot be assumed to determine its morality.

One of the objectives of an ethical analysis is to determine whether an act is morally required, morally prohibited, or morally permitted. These categories are foundational to normative reasoning, particularly in applied ethics. An action is morally required if an agent has a duty to perform it, morally prohibited if there is a duty not to perform it, and morally permissible if there is no duty either to perform or to avoid it. Therefore, morally permitted actions are those for which agents have no moral obligation either to act or to refrain. They fall within the scope of moral discretion.

In the Canadian context, MAiD is legally permitted under specific conditions, but it is not legally required. Section 241.2(1) of the Criminal Code states that a person “may” receive MAiD if all legal eligibility criteria and procedural safeguards are met. The use of the word “may” is legally significant because it confers a legal privilege to provide MAiD but does not impose a legal duty to do so (22). Even when all criteria are satisfied, no healthcare professional is under a legal obligation to perform the procedure.

The ethical analysis parallels this legal structure. While the provision of MAiD may be morally permissible in some circumstances and morally prohibited in others, it is unlikely that any circumstance could give rise to a duty to provide MAiD. The prima facie duty not to cause death, introduced later in this paper, stands in tension with the claim that MAiD could ever be morally required. Although this prima facie duty may be overridden by other moral considerations, its presence precludes any claim that professionals have a general duty to provide MAiD. This view is also unsupported by the Canadian legal framework, which permits but does not require the provision of MAiD. Accordingly, this paper does not address cases in which MAiD might be morally obligatory or categorically prohibited. Rather, it examines the specific conditions under which providing MAiD may be morally permissible, understood as a discretionary act that must be ethically justified in each case.
# Comparative Ethical Frameworks for MAiD — Clarifying the
        Canadian Model

Justifications for the provision of MAiD are typically structured around two conditions. First, the individual must make a voluntary, competent, and informed request. Second, the individual must be experiencing a medical condition that warrants assistance in dying. This second condition is often framed in terms of either a terminal prognosis, intolerable suffering, or both. Together, these two conditions form what is often referred to in the literature as the joint view (23,24). On this model, both autonomy and welfare are necessary, but individually insufficient. The autonomy condition ensures that the request reflects a voluntary and informed decision by a competent individual. The welfare condition requires that the individual’s medical circumstances be sufficiently grave to justify the intervention. While jurisdictions differ in how they define the welfare condition, for example, some require a terminal diagnosis while others require intolerable suffering, the joint view maintains that neither autonomy nor medical condition alone is enough to ethically justify the provision of MAiD.

A contrasting model, sometimes referred to as the autonomy-only view, holds that an autonomous request is sufficient to justify the provision of MAiD (25,26). On this view, suffering may be a relevant subjective motivation, but it is not a necessary condition of eligibility. The ethical permissibility of MAiD, on this account, derives solely from the individual’s autonomous decision-making authority. So long as the person has capacity, acts voluntarily, and provides informed consent, the professional’s role is to facilitate the person’s autonomous choice.

The Canadian legal framework purports to adopt the joint view model. The Criminal Code sets out eligibility criteria that include administrative requirements, autonomy-related requirements, and the presence of a grievous and irremediable medical condition. Judicial interpretations have reinforced this model. In *Carter*, the Supreme Court held that MAiD should be permitted only for competent individuals who are affected by a grievous and irremediable medical condition that causes intolerable suffering. These legal and jurisprudential elements reflect a formal commitment to both autonomy and welfare, consistent with the joint view.

Despite this formal structure, the legislation permits interpretations of the eligibility criteria that may render the medically related requirements difficult to distinguish from the patient’s autonomous request. The statutory elements that define a grievous and irremediable medical condition (which include incurability, advanced decline, enduring suffering) are not formulated in a way that clearly separates them from the patient’s autonomous request for MAiD. As a result, the assessment of these criteria may, in practice, rest primarily on the patient’s own account of their condition’s incurability, the extent of their irreversible decline, the severity of their suffering, and their expressed desire to receive MAiD. While the law appears to endorse the joint view, in which both autonomy and a qualifying medical condition are both necessary, the interpretive flexibility built into the statutory language raises the question of whether the legal framework consistently maintains this dual structure or whether it permits practices that approximate the autonomy-only model.

The ethical framework proposed in this paper does not begin with a rejection of the autonomy-only view. Rather, it begins with the observation that the Canadian legal framework explicitly rejects that model and claims to adopt the joint view. The concern, therefore, is not that the autonomy-only model is necessarily incoherent. Jurisdictions such as Germany (27) and Estonia (28) have adopted autonomy-only approaches that treat suicide and assisted suicide as a matter of individual choice rather than as a medical act. These models are internally consistent because they do not frame assisted suicide as a form of healthcare, they do not impose medical eligibility criteria, and they do not require the involvement of healthcare professionals. By contrast, Canada situates MAiD within a healthcare framework while, in practice, relying almost exclusively on patient autonomy to justify it. The aim of this paper is to clarify what would be required to make the Canadian model internally coherent, given its explicit adoption of a joint view structure.
# MAiD and Professional Discretion

The provision of MAiD is not a legal duty but a legal privilege, a distinction that has significant implications for when it is ethically justifiable for a healthcare professional to provide MAiD (53). In legal theory, a claim right imposes a corresponding duty on another party. A competent patient’s right to refuse medical treatment, for example, creates a legal obligation for healthcare professionals to respect that decision, even if they believe it is not in the patient’s best interest. This duty is rooted in the concept of bodily integrity. A healthcare professional may not touch a patient without consent, which puts them under a legal obligation to obtain consent. Otherwise, they could be liable for the tort of battery. In contrast, a privilege permits an action, but the action is not a requirement. MAiD falls into this category, it is legally permitted under specific conditions, but no healthcare professional is legally required to provide it.

This distinction is explicitly reflected in section 241.2(1) of the Criminal Code, which states that “A person may receive medical assistance in dying only if they meet all of the following criteria.” In legal terms, “may” means that an action is permitted but not obligatory (54). If the law intended to impose a duty to provide MAiD, it would have used the word “must.” The permissive wording makes clear that the decision to provide MAiD remains at the discretion of the healthcare professional. Unlike a competent patient’s right to refuse treatment, which creates a legal duty to comply, even if a patient meets all the eligibility criteria for MAiD, the healthcare professional does not have a corresponding duty to perform the procedure.

The discretionary nature of MAiD is not an unintended consequence of legislative wording but a necessary structural feature of the law. The Supreme Court, in the *Carter* decision (1), recognized that MAiD must operate within a system of stringent limits and scrupulous monitoring. This requirement necessarily involves the professional judgment of healthcare professionals, who must determine whether those limits have been met in each case. Additionally, the MAiD legislation creates a narrowly controlled legal exception to the prohibition on culpable homicide. This reinforces that MAiD is a permissible but restricted act. The discretionary nature of MAiD is further demonstrated by variability in its application. Some providers adopt a more restrictive interpretation of the eligibility criteria, while others take a more permissive approach. Doctor shopping has emerged as an observable phenomenon, where some patients seek out high-volume MAiD providers known for their more flexible interpretations of eligibility (55).

Since every decision to provide MAiD involves professional discretion, ethical practice requires that this discretion be exercised in a manner that is transparent, accountable, and guided by principled ethical reasoning. Some professionals may argue that once a patient meets the legal eligibility criteria and safeguards, MAiD should be provided as a matter of course (56). However, such a position is neither a legal requirement nor a medical determination. Rather, it is a normative stance that defers entirely to the principle of respect for patient autonomy. Every decision to provide MAiD is a normative judgment about whether providing MAiD is appropriate in a given case. The next section will develop an ethical framework to structure this discretion, outlining the conditions that must be satisfied for it to be morally permissible for a healthcare professional to provide MAiD.
# Conclusion

This paper has critically examined the ethical foundation of MAiD in Canada. It demonstrates that the legal framework establishes the conditions under which a patient is considered eligible for MAiD but there is little guidance to help healthcare professionals determine when it is morally permissible to provide MAiD. A fundamental flaw in the current system is that it treats professional participation as a matter of procedural compliance rather than substantive ethical judgment. By focusing primarily on patient values, goals, and preferences, the legal criteria collapse into a verification of patient autonomy rather than an independent medical determination of a grievous and irremediable medical condition. This approach fails to recognize that professional participation in MAiD, demands an explicit ethical justification beyond mere legal eligibility.

To address this gap, this paper proposes an ethics framework grounded in the fiduciary duties of healthcare professionals and structured by the four core principles of healthcare ethics: respect for autonomy, beneficence, nonmaleficence, and justice. The framework holds that providing MAiD is morally permissible only when the patient is autonomous, understood in terms of informed consent, voluntariness, and capacity; when the intervention aligns with the duties of beneficence and nonmaleficence, requiring the professional to exercise independent clinical judgment; and when the request arises from a context of justice, exemplified by the cruel choice, in which a medical condition impairs the patient’s ability to act on their autonomous wish to die without assistance. This approach ensures that MAiD is not merely a discretionary affirmation of patient autonomy but a medically and ethically permitted intervention grounded in professional fiduciary duties.

## Références

1Carter v Canada (Attorney General), 2015 SCC 5, [2015] 1 SCR 331 at para 105.

C, Lemmens T, Kim SYH. Canadian medical assistance in dying: provider concentration, policy capture, and need for reform. Am J Bioeth. 2025;25(5):6-25.

3Health Canada. Fifth Annual Report on Medical Assistance in Dying in Canada. Ottawa; 11 Dec 2024.

E, Downie J, White BP. Practitioners’ experiences with 2021 amendments to Canada’s medical assistance in dying law: a qualitative analysis. Palliat Care Soc Pract. 2023;17:26323524231218282.

5Medical Assistance in Dying. Criminal Code, RSC 1985, c C-46, s 241.1.

6Law Reform Commission of Canada. Euthanasia, aiding suicide and cessation of treatment. Working Paper 28. Ottawa; 1983.

7Law Reform Commission of Canada. Report 20: Euthanasia, Aiding Suicide and Cessation of Treatment. Ottawa; 1983.

8Keyserlingk EW. Assisted suicide, causality and the Supreme Court of Canada. McGill Law J. 1994;39(2):285-328.

9Senate of Canada. Of Life and Death - Final Report. Special Senate Committee on Euthanasia and Assisted Suicide, 35<sup>th</sup> Parliament, 1<sup>st</sup> Session. Ottawa; 1994.

AM, Frank CE, Keller M, McCullough JO, Rampton V. Language matters: the semantics and politics of “assisted dying”. Hastings Cent Rep. 2024;54(5):3-7.

11Collège des médecins du Québec. Physicians, appropriate care and the debate on euthanasia: a reflection. Montréal; 2 Nov 2009.

12Commission spéciale sur la question de mourir dans la dignité. Mourir dans la dignité: rapport de la Commission spéciale sur la question de mourir dans la dignité. Québec: Assemblée nationale du Québec; 2012.

13Assemblée nationale du Québec. Bill 52, An Act respecting end-of-life care, 2014, c 2. Québec: Gouvernement du Québec; 2014.

R, Christie T. Assisted suicide and euthanasia: language lost in MAiD. Can J Bioeth. 2024;7(2-3):159-65.

15Government of Canada. An Act to amend the Criminal Code and to make related amendments to other Acts (medical assistance in dying), SC 2016, c 3 (Bill C-14).

16Government of Canada. An Act to amend the Criminal Code (medical assistance in dying), SC 2021, c 2 (Bill C-7).

17Government of Canada. Criminal Code, RSC 1985, c C‑46, ss. 241.2 (as amended by SC 2016, c 3; SC 2021, c 2).

18Parliament of Canada. How a bill becomes law. Ottawa; 2021.

19Beauchamp TL, Childress JF. Principles of Biomedical Ethics. 8<sup>th</sup> ed. New York: Oxford University Press; 2019.

WD. The Right and the Good. Oxford: Clarendon Press; 1930/2002.

21Truth and Reconciliation Commission of Canada. Honouring the Truth, Reconciling for the Future: Summary of the Final Report of the Truth and Reconciliation Commission of Canada. Ottawa; 2015.

22Government of Canada. Interpretation Act, RSC 1985, c I‑21, s 11. Ottawa; 1985(rev 2025).

Haan J. The ethics of euthanasia: advocates’ perspectives. Bioethics. 2002;16(2):154-72.

LW. Physician-Assisted Death: What Everyone Needs to Know. New York: Oxford University Press; 2017.

J, Mathison E. The case for an autonomy‑centered view of physician‑assisted death. J Bioeth Inq. 2020;17(3):345-56.

E. An autonomy-based approach to assisted suicide: a way to avoid the expressivist objection against assisted dying laws. J Med Ethics. 2023;49(7):497-501.

27Germany. Judgment of the Federal Constitutional Court (BVerfG) of 26 February 2020 – 2 BvR 2347/15. Karlsruhe: Bundesverfassungsgericht; 20 Feb 2020.

28Estonia. Supreme Court judgment in case 1-21-12780. Tallinn: Supreme Court of Estonia; 7 May 2025.

29A.C. v. Manitoba (Director of Child and Family Services), 2009 SCC 30, [2009] 2 SCR 181. Ottawa: Supreme Court of Canada; 2009.

30Belgium. Act Concerning Euthanasia. Brussels: Belgian Official Gazette; 28 May 2002.

31Government of the Netherlands. Termination of Life on Request and Assisted Suicide (Review Procedures) Act. The Hague; 1 Apr 2022.

SA, Mauron A. Assisted suicide and euthanasia in Switzerland: allowing a role for non-physicians. BMJ. 2003;326(7383):271-3.

33MAID Practice Standards Task Group. Model Practice Standard for Medical Assistance in Dying (MAID). Ottawa: Health Canada; 2023.

34MAID Practice Standards Task Group. Advice to the Profession: Medical Assistance in Dying (MAiD). Ottawa: Health Canada; 2023.

35Norberg v Wynrib, [1992] 2 S.C.R. 226.

36Hopp v Lepp, [1980] 2 SCR 192, 112 DLR (3d) 67.

37Reibl v Hughes, [1980] 2 S.C.R. 880.

38Government of Canada. Homicide. Criminal Code, RSC 1985, c C-46, s 222.

39Nancy B. v Hôtel-Dieu de Québec, [1992] RJQ 789 (Que Sup Ct).

40Starson v Swayze, 2003 SCC 32, [2003] 1 SCR 722.

LH, Meisel A, Lidz CW. Tests of competency to consent to treatment. Am J Psychiatry. 1977;134(3):279-84.

PS. Assessment of patients’ competence to consent to treatment. NEJM. 2007;357(18):1834-40.

43Appel JM. Legal and ethics considerations in capacity evaluation for medical aid in dying. J Am Acad Psychiatry Law. 2024;52(3):311-26.

E, Kelly M, McMorrow T, Tremblay-Huet S, Hennawy M. Assessment of capacity to give informed consent for medical assistance in dying: a qualitative study of clinicians’ experience. CMAJ Open. 2021;9(2):E358-63.

45In re Quinlan, 70 NJ 10, 355 A2d 647 (NJ 1976).

46Cruzan v. Director, Missouri Department of Health, 497 US 261 (1990).

47Québec. Bill 11, An Act to amend the Act respecting end-of-life care and other legislative provisions. 1st Sess, 43rd Leg, Québec, 2023.

48Canadian Association of MAiD Assessors and Providers. The Interpretation and Role of ‘Reasonably Foreseeable’ in MAiD Practice. CAMAP; Feb 2022.

49Picard EI, Robertson GB. Legal Liability of Physicians and Hospitals in Canada. 5<sup>th</sup> ed. Toronto: Thomson Carswell; 2017.

J, Manduca-Barone A, Zurbrigg P. Medical assistance in dying: a review of related Canadian news media texts. J Med Humanit. 2023;44(2):167-86.

K, Mullin A. Choosing death in unjust conditions: hope, autonomy and harm reduction. J Med Ethics. 2024;50(6):407-12.

T, Li M. Medically assisted dying in Canada and unjust social conditions: a response to Wiebe and Mullin. J Med Ethics. 2024;50(6):423-24.

WN. Some fundamental legal conceptions as applied in judicial reasoning. Yale Law J. 1913;23:16-59.

54Department of Justice Canada. Present indicative. Legistics. 29 Aug 2022.

R, Maher J, Gaind KS, Lemmens T. The realities of Medical Assistance in Dying in Canada. Palliat Support Care. 2023;21(5):871-8.

J, Schuklenk U. Social determinants of health and slippery slopes in assisted dying debates: lessons from Canada. J Med Ethics. 2021;47(10):662-9.

57McInerney v MacDonald, [1992] 2 SCR 138.

58Canadian Medical Protective Association. Medico-Legal Handbook for Physicians in Canada. Version 9.0. Ottawa: CMPA; May 2021 (rev. Oct 2024).

59Rodriguez v. British Columbia (Attorney General), [1993] 3 S.C.R. 519.

J. A Theory of Justice. Cambridge: Harvard University Press; 1971.

61Oregon Health Authority. Oregon Death with Dignity Act: 2022 Data Summary. Portland; 2023.

62Washington State Department of Health. Washington Death with Dignity Act: 2022 Report. Olympia; 2 Jun 2023.

63California Department of Public Health. California End of Life Option Act: 2022 Data Report. Sacramento; Jul 2023.

64Health Canada. First Annual Report on Medical Assistance in Dying in Canada 2019. Ottawa; Jul 2020.

65Health Canada. Second Annual Report on Medical Assistance in Dying in Canada 2020. Ottawa; Jun 2021.

66Health Canada. Third Annual Report on Medical Assistance in Dying in Canada 2021. Ottawa; Jul 2022.

67Health Canada. Fourth Annual Report on Medical Assistance in Dying in Canada 2022. Ottawa; Oct 2023.

68Truchon c Procureur général du Canada, 2019 QCCS 3792.

LD, Bastidas-Bilbao H, Cappe V, et al. Medical assistance in dying for mental illness as a sole underlying medical condition and its relationship to suicide: A qualitative lived experience-engaged study. Can J Psychiatry. 2024;69(5):314-25.

C, Kelly M, Spiegel L, Baylis PJ, Dembo J, Wiebe E. Patient experiences with requests for medical assistance in dying: Perspectives of those with complex chronic conditions. Can Fam Physician. 2024;70(1):41-7.