The regulation of euthanasia by the criminal law has tended to be one of the more contentious areas of medical law, and continues to be the subject of debate. Few areas of the criminal law have been so consistently the target of reformist pressure, and certainly few areas have so strongly resisted change. Understandably, legislators are unwilling to involve themselves in a matter of law reform which engenders such moral disagreement, and it is significant that only two jurisdictions-The Netherlands and the Australian Northern Territories-have made any substantial change in their legal practice in this area. In other countries, including the UK, the courts and legislators have consistently refused to remove the fundamental criminal law objection to the practice of euthanasia. This is not to say, of course, that the courts have failed to recognise the medical subtleties in medical treatment at the end of life; in several important decisions, the courts in Britain have considered the boundaries of the criminal law's protection of life and have offered guidelines for doctors facing the delicate issues associated with treating the dying patient. Yet, in spite of several helpful decisions from the courts, the basic principle remains firmthe criminal law does not countenance the taking of life, no matter how good the motive. This means that there are very clear legal limits to the extent to which doctors can follow their individual consciences in this area.