Dijana Gracin, Jadranka Herceg, Žana Kovačić
Does a human being have the right to a dignified death? This question inevitably turns
to the problem of euthanasia as well. Euthanasia is a topic that can be approached in
a number of ways, including religious, sociological, medical, and ethical approaches.
The aim of this paper is to provide, first and foremost, a comparative account of the
penological aspects of euthanasia. The authors explain the concepts of euthanasia and
assisted suicide and analyse the problem in light of the legal solutions in Hungary,
France, Germany, Belgium, and the Netherlands. These analyses are based on the
study of pertinent literature, analysis of a case from the practice of the European
Court of Human Rights, and use of the comparative method. The study examines the
situation in Croatia de lege lata, where active euthanasia is prohibited and death on
demand is recognized as a privilege murder. Following the discussion, the authors
suggest that a specific euthanasia law be passed as a potential de lege ferenda solution.
euthanasia, death on demand, assisted suicide, legislation, comparative analysis