Abstract

The paper aims to analyse, from a comparative perspective, certain aspects of the role of medical ethics in France, Italy and Germany. Given the variety of models of the relationship between Law and Professional Ethics in Europe, the comparative analysis addresses convergences and divergences as to the scope of codes of medical ethics, their form and legal value. Since the actual scope of professional medical ethics depends on factors which, in the various countries, characterise both the professional community which draws it up and the legal order in which the process of working out and developing the rules of medical ethics takes place, the paper combines a formal and substantial perspective in dealing with the relationships between the codes of medical ethics and the sources of law in France, Italy and Germany.