in such unsettled matters, refrained from clarifying the issue further. End of life Euthanasia is the act of deliberately ending a person's life to relieve suffering. The only countries that have legalised euthanasia are Spain, Belgium, Luxembourg, the Netherlands, Canada and Colombia. In the United Kingdom, the Suicide Act 1961 legalised the attempt to take one's own life, but it kept illegal the assistance of another's death. Case law 1. Legal and administrative framework a. Requirement for laws prohibiting the taking of life. b. Euthanasia, pretty much left to the margin of appreciation. c. No right to die as stated in Pretty v UK 2000. d. Amnesties of criminals – Dujardin v France 1991 – an amnesty is not a breach unless it is part of a systematic effort to prevent prosecution and punishment for murder... e. Regulation of activities posing risk to life – Nachova v Bulgaria; MP were allowed to use lethal force when arresting military personnel. - Oneryildiz v Turkey – dangerous industrial activity must be regulated and licensed and monitored. 2. Law enforcement machinery Calvelli and Ciglio v Italy 2002 – Police delay in investigation meant time restrictions is taking civil action against negligent doctor, thus there was a breach on the part of the state for its failure to properly investigate. Vo v France 2004 – Involuntary abortion by a doctor, NO breach because the law did not encompass a 21-week-old foetus, whilst an amnesty applied to the other offense. FURTHER, the victim had recourse to civil litigation, which was deemed sufficient. Preventive measures to protect life LBC v UK –‘appropriate steps’ to protect life principle... LCB had leukaemia, which she blamed on her father's presence at nuclear testing site, the UK had failed to inform them of the risks...held, and there was No liability because the injuries complained of were not reasonably foreseeable at the time with the information they had. Oneryildiz v Turkey, the LCB obligation to take appropriate steps applies in the context of any activity, public or private in which the right to life is at risk...especially industrial activities dangerous by nature. Authorities knew or ought to have known of the risks and should have taken measures, which they did not thus breaching Article 3. The LBC obligation applies more commonly to criminal cases. In Osman v UK 1998 – THE OSMAN OBLIGATION: The Osman criteria in action; Gongadez v Ukraine