Australia and the United States
Although VAE and PAS have been legally condoned in the Netherlands since 1984, this condonation was effected by caselaw rather than legislation. The world's first legislation permitting PAS was enacted by a referendum in Oregon, USA, in 1994. Its implementation was, however, delayed pending legal challenge until 1997 when it was confirmed by a second referendum. The first PAS legislation to come into force was enacted by the legislature of the Northern Territory of Australia in 1995. Seven people sought to make use of this Act before it was repealed by the Federal Parliament of Australia in 1997.
Part IV, comprising chapters 14 and 15, considers whether the legislation as framed and enforced in these two jurisdictions meets the criticisms about lack of effective control to which the Dutch approach has proved so vulnerable.