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 is direct.
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.