ABSTRACT

Informed consent for medical treatment is often said to be a legal issue which is as much discussed as little understood. This article develops an analysis of the concept of informed consent particularly at the end of life from a comparative perspective, dividing a number of relevant countries into two models – one partially open and one partially closed – neither of them allowing for extreme solutions such as the right to die, on the one hand, and the duty to be kept artificially alive beyond one's own idea of human dignity, on the other. According to such distinction, and paying particular attention to the law-in-action governing end-of-life decisions, the author considers similarities and diversities, as well as evolving common trends.