euthanasia: murder or not: a comparative approach.

background euthanasia is one of the most intriguing ethical, medical and law issues that marked whole xx century and beginning of the xxi century, sharply dividing scientific and unscientific public to its supporters and opponents. it also appears as one of the points where all three major religions (catholic, orthodox, and islamic) have the same view. they are strongly against legalizing mercy killing, emphasizing the holiness of life as a primary criterion by which the countries should start in their considerations. studying criminal justice systems in the world, the authors concluded that the issue of deprivation of life from compassion is solved on three ways. on the first place, we have countries where euthanasia is murder like any other murder from the criminal codes. second, the most numerous are states where euthanasia is murder committed under privilege circumstances. on the third place, in the western europe we have countries where euthanasia is a legal medical procedure, under requirements prescribed by the law. in this paper, authors have made a brief comparison of the solutions that exist in some islamic countries, where euthanasia is a murder, with western countries, where it represents completely decriminalized medical procedure.