القتل الرحيم دراسة مقارنة بني القانون الوضعي والتشريع اإلهلي.

Euthanasia is one of the issues that sparked controversy in medical, legal, and religious circles as the practices have led to several problems and raised legal and ethical issues that require attention and study. The debate on euthanasia has resulted in the emergence of jurisprudential trends in favor and opposition to euthanasia which then influence the legislation. This study aims to identify the provisions of euthanasia in positive law and divine legislation. It also seeks to identify the extent to which intentional euthanasia is criminalized, and the cases in which it may be considered an extenuating circumstance. The study used the analytical and comparative approach. The study found that some western legislations permit euthanasia whereas Islamic countries which laws are based on Shariah criminalized it. Euthanasia is considered intentional killing in Shariah regardless of the advantages or disadvantages of the practice. This perspective is shared by three monotheistic religions that unanimously prohibit euthanasia and considered it as a crime of killing a person without right. Although the jurists unanimously agreed on the prohibition of positive euthanasia, they differed on the prohibition of passive euthanasia. These findings may shed some light to guide the policymakers in enacting appropriate law regarding the matter [ABSTRACT FROM AUTHOR]