There is reason to expect that legalization of voluntary active euthanasia might soon be followed by strong pressure to legalize some nonvoluntary euthanasia
of incompetent patients unable to express their own wishes.
Despite this (highly qualified) backtracking by Hemlock, the route from voluntary to nonvoluntary euthanasia
The Remmelink Committee further-more found that in 45 percent of the 1,000 nonvoluntary euthanasia
cases, treatment of pain was no longer adequate to relieve the patient's suffering.
The tragedy is that there is no way to stop the slide to nonvoluntary euthanasia
once a society steps onto the slippery slope by penalizing physician-assisted suicide.
From explicit admissions to me by Dutch proponents of euthanasia, and from the corroborating information provided by the Remmelink Report and the outside studies of Carlos Gomez and John Keown, I am convinced that in the Netherlands there are a substantial number of cases of nonvoluntary euthanasia
, that is, euthanasia undertaken without the explicit permission of the person being killed.
Henk Jochemsen critically reviews Dutch court decisions on nonvoluntary euthanasia
On the other hand, it has moved from legitimation of voluntary euthanasia through nonvoluntary euthanasia
to involuntary euthanasia.