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Euthanasia

From Encyclopedia of Contemporary Jurisprudence
Author: Hamzeh Ahmadi
  • Abstract

Euthanasia means ending a person's life at their request or without it, by another person, with the intention of relieving them from unbearable pain and suffering or an incurable illness. This act may be performed using a lethal substance or by withdrawing essential care. Euthanasia is either performed by the patient, which jurists consider suicide, or it is performed by a physician or another person, which is divided into active and passive types.

In active euthanasia, a physician or another person commits the act of killing a patient who is suffering from an illness with no hope of recovery. According to contemporary jurists, active euthanasia is forbidden (*haram*), and its performance establishes the right of retribution (*qisas*) or blood money (*diyah*) for the deceased's heirs. Passive euthanasia, meaning withholding treatment from an incurable patient, is also forbidden; however, there is a difference of opinion among jurists regarding the necessity of retribution or payment of blood money.

According to jurists, the patient's consent to the act of euthanasia does not lift its prohibition. However, there is a difference of opinion on whether retribution or blood money follows if the patient gives permission for euthanasia.

Explanation of the Issue and Its Position

"Euthanasia" means ending a person's life with the intention of relieving them from unbearable pain and suffering or an incurable illness. This act may be performed by the person themselves or at their request by another. It is also possible that another person, out of compassion and pity, decides to kill the patient, or withholds necessary and essential care until the person passes away.[1] Euthanasia, with its various pronunciations, has Greek roots[2] and has been translated into Persian as "good death," "easy death," "euthanasia," and "mercy killing."[3]

Types of Euthanasia

From the perspective of its method, euthanasia is divided into two categories:

  • Direct Euthanasia: This is performed by the action of someone other than the patient—such as a physician.[4] This itself is divided into two types, active direct and passive direct, each of which can be either at the explicit request of the patient or involuntary and without the patient's request due to their incompetence to make decisions due to factors like being in a coma or unconscious:[5]
  1. Active Direct Euthanasia: A person, such as a physician, ends the patient's painful life with a lethal injection or drug.[6]
  2. Passive Direct Euthanasia: Treatment is withheld from continuing to keep an incurable patient who is in pain alive; that is, refraining from treatments that are necessary and essential to preserve the patient's life.[7]
  • Indirect Euthanasia: Lethal drugs are made available to an incurable patient to end their own life,[8] or drugs are prescribed that have death as a consequence.[9]

The jurisprudential discussion of euthanasia is separate from the topic of brain-dead patients. Thus, a jurist might permit disconnecting life support from a brain-dead patient or a patient in a coma with no hope of recovery, but the same jurist would consider passive euthanasia—withholding treatment out of compassion—to be forbidden (*haram*).[10]

History and Position

It is said that the term euthanasia was first introduced into medical culture by the 16th-century English philosopher Francis Bacon, in an essay titled "The Advancement of Learning," where he discussed a painless death.[11] In the first half of the 20th century, Thomas More, an English lawyer and philosopher, in his book "Utopia," deemed this act legitimate for terminally ill patients suffering greatly, conditional on the permission of judges and priests.[12] Since then, and especially after World War II, discussions and writings on this topic have intensified, and today it is one of the most important and controversial issues in the field of medical ethics and law.[13]

Although related topics have been addressed in past jurisprudential works in the chapters on retribution (*qisas*) and blood money (*diyah*), and within issues such as "the prohibition of killing a soul"[14] and "the impermissibility of killing someone who consents to it,"[15] and the issue of *ijhaz*Template:Note which is discussed in the chapter on jihad,[16] there has been no discussion on the rulings of euthanasia. This issue is an emergent one in the field of medical jurisprudence, which has now attracted the attention of contemporary jurists, who have addressed it in response to various inquiries.[17]

Prescriptive Ruling and Its Reasons

Shia Jurists' View

The views of Shia jurists on the prescriptive ruling of euthanasia vary based on its classification as active, passive, and indirect. However, in all cases, according to the jurists, the patient's permission and consent to perform euthanasia does not change the prescriptive ruling, i.e., the ruling of prohibition:[18]

  • Ruling on Active Euthanasia: Most contemporary Shia jurists agree on the prohibition of active euthanasia (mercy killing by a physician's action).[19]
  • Ruling on Passive Euthanasia: Many jurists have considered passive euthanasia (withholding or ceasing treatment for an incurable patient who is suffering from their illness) to be forbidden (*haram*).[20] Mirza Jawad Tabrizi has not considered continuing treatment in this condition to be obligatory.[21] Some jurists have permitted withholding treatment under specific conditions; among them, Naser Makarem Shirazi, in response to an inquiry about a person who has been in a coma for 12 years or a patient who has not regained consciousness for a long time after surgery, has said: If the patient's return to a normal state is customarily impossible, it is permissible to cease treatment.[22] Sayyid Ali Khamenei and Sayyid Abulqasim Khoei have not considered it obligatory to preserve a dying patient for whom there is no hope of recovery, and therefore, in their view, withholding treatment from this patient is not forbidden.[23] It can be said that the permissibility of withholding treatment by physicians in the answers given to these inquiries may be because in all these cases the patient had an unstable life, and if the patient has a stable life, withholding treatment is not permissible.
  • Ruling on Indirect Euthanasia: According to jurists such as Hossein-Ali Montazeri and Mohammad Fazel Lankarani, hastening the death of a patient, if performed by the patient themselves, is considered suicide and is forbidden.[24]

Evidence

The evidence that Shia jurists have used to prove the prohibition of euthanasia is as follows:

Direct Euthanasia (Active and Passive)

For the prohibition of active euthanasia, jurists have resorted to the general applicability of the evidence for the prohibition of killing a soul from the verses and narrations, and the evidence for the obligation to save a respected soul from destruction. This evidence is also cited for the prohibition of passive euthanasia:[25]

  • Verses 151 of Surah al-An'am, 33 of Surah al-Isra, and 93 of Surah al-Nisa have forbidden intentional and unjust killing, and this prohibition indicates impermissibility.[26] Mercy killing (euthanasia) is also an instance of intentional killing, therefore it is forbidden.[27]
  • In the book *Wasa'il al-Shi'a*, there is a chapter titled "The Prohibition of Killing Unjustly," under which 20 narrations are mentioned.[28] Jurists have argued from these narrations for the prohibition of killing a soul,[29] and since euthanasia is considered unjust killing, it has been declared forbidden.[30]

Indirect Euthanasia

For the prohibition of indirect euthanasia, the evidence for the prohibition of suicide in the verses and narrations and the obligation to preserve life have been used:[31]

  • From the perspective of jurists, the "verse of destruction"[32] and the verse "And do not kill yourselves. Indeed, Allah is ever Merciful to you"[33] as well as some narrations[34] indicate the prohibition of suicide and self-annihilation.[35] Based on this, indirect euthanasia, which a terminally ill patient undertakes to escape pain and suffering, is considered suicide and is forbidden.[36]
  • The evidence that indicates the prohibition of suicide also, by implication, indicates the obligation to preserve life.[37] Furthermore, according to some jurists, the obligation to preserve life is one of the rational independents (*mustaqillat 'aqliyya*) that reason alone can rule as necessary, and consequently, it leads to the discovery of the command of God Almighty.[38]

Sunni Jurists' View

The views of Sunni jurists also differ according to the various types of euthanasia:

  • Active Euthanasia: All Sunni scholars have ruled on the prohibition of killing to escape the pain of illness, as well as active euthanasia and causing the patient's death to be hastened.[39] According to the fatwa of the "Al-Azhar Fatwa Committee" in Egypt, killing a sick person, regardless of the illness, is not permissible and is considered an act of aggression. It is also forbidden for the patient to kill themselves, and the patient's permission does not make the forbidden act permissible; because they do not have ownership over their own soul to give permission to others to kill them.[40]
  • Passive Euthanasia: Passive euthanasia or withholding treatment and ceasing medical care due to hopelessness of recovery is either on the part of the patient or the physician, and there is a difference of opinion among jurists on both cases.[41] Some Hanafi, Shafi'i, Hanbali, and Zahiri jurists consider treatment and medication to be obligatory.[42] Some Maliki jurists have called medication absolutely permissible (*mubah*).[43] And some Hanafi, Maliki, and Shafi'i jurists have considered medication and treatment to be recommended (*mustahabb*).[44] According to some Hanbali jurists, treatment is not obligatory, and refraining from it out of reliance on God is preferable.[45]

Evidence

The evidence that Sunni jurists have used for the prohibition of euthanasia is as follows:

Quran

Some of the verses based on which Sunni jurists have issued a fatwa on the prohibition of euthanasia include:

  • Verses such as 151 of Surah al-An'am, 33 of Surah al-Isra, and 93 of Surah al-Nisa, which indicate the prohibition of killing a soul out of aggression and unjustly.[46]
  • Verses 195 of Surah al-Baqarah and 29 of Surah al-Nisa, which indicate the prohibition of suicide and self-annihilation.[47]

Prophetic Tradition

Some of the narrations based on which the prohibition of euthanasia has been argued are:

  • Narrations from the Prophet (s) that forbid unjustly killing a respected soul as well as suicide.[48]
  • Narrations in which wishing for death due to illness or suffering is forbidden.[49]

Practice of the Companions

It has been said that some of the companions were severely wounded in some battles due to injuries, but they endured the pain until the last moments of their lives, and it never crossed their minds to commit suicide to escape this pain and suffering or to give permission to others to kill them.[50]

Declarative Ruling and Its Reasons

Shia Jurists' View

The declarative ruling in euthanasia is the liability for retribution (*qisas*) or blood money (*diyah*) that may be incumbent upon the perpetrator. Jurists have differing opinions on this matter:

Indirect Euthanasia

Regarding the declarative ruling of euthanasia, considering the patient's permission and consent to its performance or their lack thereof, there is a difference of opinion among jurists. One of the issues that has been discussed in Shia jurisprudence in the past and can be used in this context now is that if someone tells another, "Kill me, or I will kill you," can he kill him? And if he kills him, is retribution or blood money established for him?[51] There are two views on this issue:

  1. Forfeiture of the Right to Retribution and Blood Money: According to jurists such as Muhaqqiq al-Hilli, Shahid al-Thani, the author of *Jawahir*, Sayyid Abd al-A'la Sabzevari, and Sayyid Ruhollah Khomeini, since the victim consented to his own murder, he has forfeited the right to retribution and blood money.[52]
  2. Non-forfeiture of the Right to Retribution and Blood Money: According to jurists such as Sayyid Abulqasim Khoei, Mirza Jawad Tabrizi, and Ja'far Sobhani, even with the victim's consent and permission for his own murder, the right to retribution and blood money is not forfeited.[53] Because, unlike what applies to property, a person does not have authority over their own destruction, so their permission for their own destruction does not cause the forfeiture of liability. Therefore, the general applicability of the evidence for retribution includes this case as well.[54] Sayyid Mohammad Sadiq Rouhani, in criticizing this view, has said that a person is the owner of their own life, limbs, and actions, and therefore, with permission and consent to their own destruction and murder, the right to retribution and blood money is forfeited.[55]

Passive Euthanasia

Examining the declarative ruling of passive euthanasia or withholding treatment from a patient suffering from their illness depends on which of the titles "prohibition of killing a soul" or "obligation to save a respected soul" applies to it.[56] According to Mohammad Reza Ansari Qomi, from a customary perspective, the issue falls under the title "obligation to save a respected soul"; because the act of killing has not been committed by him, but rather he has simply not saved the patient from death.[57] And according to Allamah al-Hilli and the author of *Jawahir*, whoever sees a person in a state of peril and does not save them—while being able to save them—although the person has committed a sin, they are not liable (for retribution or blood money).[58] Based on this, if a physician does not treat a patient and they die as a result of withholding treatment, although the physician has committed a sin, they are not liable, and the deceased's heirs do not have the right to retribution or blood money.[59]

Active Euthanasia

If a physician or another person intentionally kills an incurable patient who is suffering from their illness, without their permission, even with the intention of compassion and pity, it has all the elements of intentional murder, and they have committed intentional murder. This case is covered by the general applicability of the establishment of the right to retribution or blood money for the victim's guardian.[60]

Sunni Jurists' View

It is said that most Sunni jurists have considered killing a patient out of compassion to be an instance of intentional murder, for which retribution is established.[61] Of course, some jurists are of the opinion that the patient's permission forfeits retribution—but not blood money—because there is an element of doubt (*shubha*), and doubt forfeits retribution.[62] According to others, the patient's permission not only forfeits retribution but also blood money; because the murdered patient, by their permission, has waived their right to their own blood.[63]

Study Resources

Template:Main Some of the study resources on euthanasia in Shia and Sunni jurisprudence include:

  • The book "*Qatl az ruy-i Tarahhom (Utanazi) dar Ayineh-ye Fiqh*" (Mercy Killing (Euthanasia) in the Mirror of Jurisprudence), by Sayyed Mohsen Mortazavi: After conceptualizing the term euthanasia, stating its types and history, it examines its jurisprudential ruling in Shia and Sunni jurisprudence. The book has been published in 143 pages by the Imam Khomeini Institute.
  • The book "*Baz'andishi-ye Qatl-e Tarahhom-Amiz (Utanazi) dar Fiqh-e Islami va Huquq-e Mozu'eh*" (Rethinking Mercy Killing (Euthanasia) in Islamic Jurisprudence and Positive Law), by Kazem Khosravi: It first examines the concept of euthanasia and provides a history of the discussion, then examines the legal and jurisprudential foundations of euthanasia. The book has been published in 116 pages by Razavi University of Islamic Sciences.
  • The book "*Al-Qatl al-Rahim: Dirasa Muqarana bayn al-Shari'a al-Islamiyya wa al-Qanun al-Wad'i*" (Mercy Killing: A Comparative Study between Islamic Sharia and Positive Law), based on a thesis, written by Kulthum al-'Ammari and Sa'ida Ben Hami. After a general overview of the definition of euthanasia, its types, and history, the book examines the jurisprudential ruling of the issue from the perspective of Sunni jurisprudence and compares it with the laws of Algeria.

Footnotes

  1. ↑ Khosravi, *Baz'andishi-ye Qatl-e Tarahhom-Amiz...*, p. 20.
  2. ↑ Biggs, Euthanasia: Death with Dignity and the Law, 2001, p. 12
  3. ↑ Khosravi, *Baz'andishi-ye Qatl-e Tarahhom-Amiz...*, p. 17.
  4. ↑ Sadeghi, "A Jurisprudential and Legal Study of Euthanasia," p. 103.
  5. ↑ Parsapour et al., "Euthanasia, Explanation and Ethical Analysis," p. 3.
  6. ↑ Qasemi, *Danshnamah-i Fiqh-i Pizishki*, 2016, vol. 3, p. 323.
  7. ↑ Qasemi, *Danshnamah-i Fiqh-i Pizishki*, 2016, vol. 3, p. 323.
  8. ↑ Qasemi, *Danshnamah-i Fiqh-i Pizishki*, 2016, vol. 3, p. 323.
  9. ↑ Parsapour et al., "Euthanasia, Explanation and Ethical Analysis," p. 3.
  10. ↑ For example, see Makarem Shirazi, Naser, *Istifta'at-i Jadid*, vol. 1, pp. 479-480; Khoei & Tabrizi, *Ahkam-i Jami'-i Masa'il-i Pizishki*, p. 280; Khoei, *Fiqh al-A'dhar al-Shar'iyya wa al-Masa'il al-Tibbiyya*, p. 198.
  11. ↑ Vecchio and others, "Brief history of Euthanasia and the contribution of medical and surgical ethics to the cultural debate," p. 185.
  12. ↑ Vecchio and others, "Brief history of Euthanasia and the contribution of medical and surgical ethics to the cultural debate," p. 185.
  13. ↑ Afzali and Marzbandi, "Euthanasia in the History of Medicine," p. 67.
  14. ↑ Muhaqqiq al-Hilli, *Shara'i' al-Islam*, vol. 4, p. 180.
  15. ↑ Muhaqqiq al-Hilli, *Shara'i' al-Islam*, vol. 4, p. 185.
  16. ↑ A group of authors, *Farhang-e Fiqh-e Farsi*, vol. 1, p. 284.
  17. ↑ Al-'Ammari and Ben Hami, *Al-Qatl al-Rahim: Dirasa Muqarana bayn al-Shari'a al-Islamiyya wa al-Qanun al-Wad'i*, p. 9.
  18. ↑ Fazel Lankarani, *Ahkam-i Bimaran va Pizishkan*, p. 152; Makarem Shirazi, *Istifta'at-i Jadid*, vol. 1, p. 479.
  19. ↑ Montazeri, *Ahkam-i Pizishki*, p. 122; Fazel Lankarani, *Ahkam-i Bimaran va Pizishkan*, p. 152; Makarem Shirazi, *Istifta'at-i Jadid*, vol. 1, p. 479; Makarem Shirazi, *Ahkam-i Pizishki*, p. 116; Khoei and Tabrizi, *Ahkam-i Jami'-i Masa'il-i Pizishki*, pp. 280-281; Safi Golpayegani, *Istifta'at-i Pizishki*, p. 100; Alavi Gorgani, *Istifta'at-i Pizishki*, p. 40; Qasemi, *Danshnamah-i Fiqh-i Pizishki*, vol. 3, p. 305.
  20. ↑ Safi Golpayegani, *Istifta'at-i Pizishki*, p. 100; Makarem Shirazi, *Istifta'at-i Jadid*, vol. 1, p. 479; Montazeri, *Ahkam-i Pizishki*, p. 122.
  21. ↑ Khoei and Tabrizi, *Ahkam-i Jami'-i Masa'il-i Pizishki*, p. 281.
  22. ↑ ["Ending the life of patients who have been unconscious for years,"](https://makarem.ir/main.aspx?lid=0&typeinfo=21&catid=46873) Information website of the office of Grand Ayatollah Makarem Shirazi.
  23. ↑ ["Rulings on Euthanasia (Mercy Killing),"](https://www.leader.ir/fa/book/64/احکام-پزشکی) Information website of the office of the Supreme Leader; Khoei, *Fiqh al-A'dhar al-Shar'iyya wa al-Masa'il al-Tibbiyya*, p. 198.
  24. ↑ Montazeri, *Ahkam-i Pizishki*, p. 123; Qasemi, *Danshnamah-i Fiqh-i Pizishki*, vol. 3, p. 303.
  25. ↑ Makarem Shirazi, *Istifta'at-i Jadid*, vol. 1, p. 479; Mortazavi, *Qatl az ruy-i Tarahhom (Utanazi) dar Ayineh-ye Fiqh*, p. 92.
  26. ↑ Najafi, *Jawahir al-Kalam*, vol. 42, pp. 8-9.
  27. ↑ Mortazavi, *Qatl az ruy-i Tarahhom (Utanazi) dar Ayineh-ye Fiqh*, p. 52; Qasemi, *Danshnamah-i Fiqh-i Pizishki*, vol. 3, p. 306.
  28. ↑ Hurr al-'Amili, *Wasa'il al-Shi'a*, vol. 29, p. 9.
  29. ↑ Najafi, *Jawahir al-Kalam*, vol. 42, pp. 9-10.
  30. ↑ Makarem Shirazi, *Istifta'at-i Jadid*, vol. 1, p. 479.
  31. ↑ Mortazavi, *Qatl-e Tarahhom (Utanazi) dar Ayineh-ye Fiqh*, p. 47.
  32. ↑ Quran 2:195.
  33. ↑ Quran 4:29.
  34. ↑ Hurr al-'Amili, *Wasa'il al-Shi'a*, vol. 19, p. 379.
  35. ↑ Muhaqqiq Ardibili, *Zubdat al-Bayan*, p. 428; Tabataba'i, *Al-Mizan fi Tafsir al-Qur'an*, vol. 4, p. 320; Makarem Shirazi, *Tafsir-e Nemuneh*, vol. 3, p. 356; Mortazavi, *Qatl az ruy-i Tarahhom (Utanazi) dar Ayineh-ye Fiqh*, pp. 47, 53.
  36. ↑ Qasemi, *Danshnamah-i Fiqh-i Pizishki*, vol. 3, p. 306.
  37. ↑ Soltani and Karachiyan Thani, "Jurisprudential and Legal Proof of the Rule of the Necessity of Preserving Life," p. 96.
  38. ↑ Fazel Lankarani, "Preserving life is one of the most important obligations," Islamic Republic News Agency.
  39. ↑ Abd al-Hamid Isma'il, "Al-Qatl al-Rahim wa Mawqif Shari'at al-Islamiyya Minhu: Dirasa Fiqhiyya Muqarana," p. 536; Mortazavi, *Qatl az ruy-i Tarahhom (Utanazi) dar Ayineh-ye Fiqh*, p. 118.
  40. ↑ Al-'Ammari, Ben Hami, *Al-Qatl al-Rahim: Dirasa Muqarana bayn al-Shari'a al-Islamiyya wa al-Qanun al-Wad'i*, p. 58.
  41. ↑ Abd al-Hamid Isma'il, "Al-Qatl al-Rahim wa Mawqif Shari'at al-Islamiyya Minhu: Dirasa Fiqhiyya Muqarana," p. 540.
  42. ↑ Abd al-Hamid Isma'il, "Al-Qatl al-Rahim wa Mawqif Shari'at al-Islamiyya Minhu: Dirasa Fiqhiyya Muqarana," p. 541.
  43. ↑ Ibn 'Abd al-Barr, *Al-Kafi fi Fiqh Ahl al-Madina*, vol. 2, p. 1142.
  44. ↑ Abd al-Hamid Isma'il, "Al-Qatl al-Rahim wa Mawqif Shari'at al-Islamiyya Minhu: Dirasa Fiqhiyya Muqarana," p. 541.
  45. ↑ Al-Hajjawi, *Al-Iqna' fi Fiqh al-Imam Ahmad ibn Hanbal*, vol. 1, p. 210; Buhuti, *Kashf al-Qina' 'an Matn al-Iqna'*, vol. 2, p. 76.
  46. ↑ Abd al-Hamid Isma'il, "Al-Qatl al-Rahim wa Mawqif Shari'at al-Islamiyya Minhu: Dirasa Fiqhiyya Muqarana," p. 533.
  47. ↑ Al-'Ammari and Ben Hami, *Al-Qatl al-Rahim: Dirasa Muqarana bayn al-Shari'a al-Islamiyya wa al-Qanun al-Wad'i*, p. 55.
  48. ↑ Bukhari, *Sahih al-Bukhari*, vol. 4, p. 72; Muslim, *Sahih Muslim*, vol. 1, p. 103; Zubbar, Abd al-Awi, *Al-Qatl al-Rahim bayn al-Tahrim wa al-Ibaha*, p. 78.
  49. ↑ Muslim, *Sahih Muslim*, vol. 4, p. 2064; Zubbar, Abd al-Awi, *Al-Qatl al-Rahim bayn al-Tahrim wa al-Ibaha*, p. 79; Abd al-Hamid Isma'il, "Al-Qatl al-Rahim wa Mawqif Shari'at al-Islamiyya Minhu: Dirasa Fiqhiyya Muqarana," p. 534.
  50. ↑ Zubbar, Abd al-Awi, *Al-Qatl al-Rahim bayn al-Tahrim wa al-Ibaha*, p. 80.
  51. ↑ Ansari, "Mercy Killing," p. 133.
  52. ↑ Muhaqqiq al-Hilli, *Shara'i' al-Islam*, vol. 4, p. 185; Najafi, *Jawahir al-Kalam*, vol. 42, p. 54; Shahid al-Thani, *Masalik al-Afham*, vol. 15, p. 89; Sabzevari, *Muhadhdhab al-Ahkam*, vol. 28, p. 199; Khomeini, *Tahrir al-Wasilah*, vol. 2, p. 489.
  53. ↑ Khoei, *Mabani Takmilat al-Minhaj*, vol. 42, p. 18; Tabrizi, *Tanqih Mabani al-Ahkam*, pp. 47-48; Sobhani, *Ahkam al-Qisas fi al-Shari'ah al-Islamiyyah al-Gharra'*, p. 93.
  54. ↑ Khoei, *Mabani Takmilat al-Minhaj*, vol. 42, p. 18; Tabrizi, *Tanqih Mabani al-Ahkam*, pp. 47-48; Sobhani, *Ahkam al-Qisas fi al-Shari'ah al-Islamiyyah al-Gharra'*, p. 93.
  55. ↑ Rouhani, *Fiqh al-Sadiq*, vol. 26, p. 34.
  56. ↑ Ansari Qomi, "Mercy Killing," p. 138.
  57. ↑ Ansari Qomi, "Mercy Killing," p. 138.
  58. ↑ Allamah al-Hilli, *Tahrir al-Ahkam*, vol. 5, p. 551; Najafi, *Jawahir al-Kalam*, vol. 43, p. 153.
  59. ↑ Ansari Qomi, "Mercy Killing," p. 141.
  60. ↑ Safi Golpayegani, *Istifta'at-i Pizishki*, p. 100; Ansari Qomi, "Mercy Killing," p. 138.
  61. ↑ Abu Zahra, *Al-Jarimah wa al-'Uqubah fi al-Fiqh*, p. 389.
  62. ↑ Abu Zahra, *Al-Jarimah wa al-'Uqubah fi al-Fiqh*, p. 389.
  63. ↑ Abu Zahra, *Al-Jarimah wa al-'Uqubah fi al-Fiqh*, p. 389.

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