Regarding the Errors in the Foreword "Euthanasia Goes Beyond the Bounds" in Bioethics (Japan Association of Bioethics, Vol. 35, No. 1, Sep. 2025) July 5, 2026 | Last Updated: July 5, 2026 | Shinichiro Morinaga

"If we are to examine the issue of (legalizing) euthanasia, our examination cannot be adequate without taking into consideration such criticisms and concerns raised by UN committees and similar bodies. I would like to confirm that much here for the time being." The Foreword concludes with these words.

However, upon reading the referenced UN Committee on the Rights of Persons with Disabilities Report (Committee on the Rights of Persons with Disabilities, Concluding observations on the combined second and third periodic reports of Canada, 15 April 2025; hereinafter referred to as the "UN Report"), it immediately became clear that several compounding errors have resulted in a report that has been (even if unintentionally) "fabricated" and presented before our eyes as "fact."

① The Foreword author’s (hereinafter "Mr. A") summary of the Quebec Superior Court ruling mentioned in the UN Report has been altered (intentionally?) when compared against the original text of the UN Report. ② The content attributed to the Quebec Superior Court ruling within the UN Report has itself been altered (intentionally?) when compared against the actual text of the Quebec Superior Court ruling. ③ Furthermore, the author has (intentionally?) employed rhetorical manipulation regarding the UN Report.

The Canadian euthanasia legislation criticized in the UN Report is the new euthanasia law (Bill C-7; assented to March 17, 2021). This law was enacted in response to the Quebec Superior Court ruling (Truchon c. Procureur général du Canada, 2019 QCCS 3792 (CanLII)) regarding Bill C-14 (An Act to amend the Criminal Code and to make related amendments to other Acts (medical assistance in dying), June 17, 2016).

Let us compare the content of the Quebec Superior Court ruling at issue in this Foreword across three versions: the actual text of the Superior Court ruling, the UN Report, and Mr. A's Japanese translation.

• Quebec Superior Court Ruling (Key Points): Ruled that the requirement of "reasonably foreseeable natural death" (MAID eligibility criteria (2)(d)) under the federal legislation infringed upon the plaintiffs' fundamental rights under Section 7 [1] and Section 15 [2] of the Canadian Charter of Rights and Freedoms. Similarly, the requirement of "end-of-life" (MAID eligibility criteria (c)) under the Quebec legislation was also found to violate Section 15 of the Charter.
• The UN Report: "...which fundamentally changed the whole premise of medical assistance in dying – from one restricted to cases in which natural death is reasonably foreseeable to one that establishes the possibility of medically assisted dying for persons with disabilities."
• Mr. A's Translation: "Delivered a ruling that expanded [eligibility] from end-of-life cases to those based on disability."

① Mr. A's Mistranslation (The Gravest Error) — Translation of the UN Report's Description of the Quebec Superior Court Ruling

The UN Report states the following:

"...which fundamentally changed the whole premise of medical assistance in dying – from one restricted to cases in which natural death is reasonably foreseeable to one that establishes the possibility of medically assisted dying for persons with disabilities."

However, Mr. A translates this as:

"Delivered a ruling that expanded [eligibility] from end-of-life cases to those based on disability."

In other words, according to Mr. A's translation, even a "physical disability" has become a permissible justification for euthanasia. Under this interpretation, one could be euthanized simply because one has a physical disability—making it sound akin to Hitler’s T4 Program orders to grant "mercy deaths" to persons with disabilities. Consequently, this would imply that Canada's euthanasia legislation is sliding down a slippery slope from voluntary euthanasia to non-voluntary euthanasia, thereby justifying the title of this Foreword: "Euthanasia Goes Beyond the Bounds."

However, this translation commits two major errors. First, it conflates "persons with disabilities" with "disability itself." A person with a disability is a human being who happens to have a disability; they are not an "entity" that forfeits human rights merely by having one. Second, it treats disability as a sufficient condition for euthanasia. The original English text does not state that disability is a sufficient condition for euthanasia. It states that changes were made so that "patients with physical disabilities could also (provided other conditions are met) access medical assistance in dying." Therefore, contrary to Mr. A's assertion, the new Canadian law did not "enable persons with disabilities to be euthanized on the grounds of their disability."

② What, Then, is the Error in the UN Report?

"Changed to one that establishes the possibility of medically assisted dying (MAID) for persons with disabilities" — Reading this description of the court ruling in the UN Report leads one to believe that "persons with disabilities have become able to access euthanasia" solely as a result of this legislative amendment. Consequently, the UN Report expresses concern that the legislative changes might drive persons with disabilities toward euthanasia.

In reality, however, persons with disabilities could access MAID even prior to the legislative amendment, provided they met the eligibility requirements. Yet, the report states as if this recent amendment changed the law so that "persons with disabilities could now access MAID"—suggesting that a grave situation has emerged wherein persons with disabilities are now targeted for euthanasia.

To reiterate the difference between the Court Ruling and the UN Report: The Court Ruling recognized access to euthanasia for patients with "a grievous and irremediable medical condition, illness, or disability," even if "natural death is not reasonably foreseeable" (regarding federal Criminal Code C-14) or even if they are "not at the end of life" (regarding Quebec provincial law). Conversely, the UN Report interprets this as meaning that persons with disabilities previously could not access euthanasia, but "have now become able to access it." However, even under the previous euthanasia legislation, persons with disabilities could access MAID (if natural death was foreseeable). Therefore, the UN Report's assertion that this amendment changed the law "to establish the possibility of MAID for persons with disabilities" is based on an incorrect understanding. Driven by this misconception, the UN Report viewed and criticized the ruling as a regression toward a state-sponsored eugenics program.

Furthermore, reading the new law (Bill C-7) reveals that a new "safeguard" has been instituted: in cases where "natural death is not reasonably foreseeable," there must be "a minimum period of 90 days between the day of the first assessment and the day on which MAID is provided." Thus, the law did not simply throw open the doors to patients not at the end of life; protective barriers were also put in place.

As demonstrated above, the UN Report incorrectly understood the Quebec Superior Court ruling as having "changed the law so that persons with disabilities could access euthanasia" when they already could; Mr. A further mistranslated this summary to mean that the law was changed "to allow euthanasia on the grounds of disability"; and based on this, he criticized the legalization of euthanasia by claiming that initial requirements inevitably relax, causing euthanasia to "deviate beyond its bounds" from voluntary to non-voluntary death. He then demands that this fabricated critique of euthanasia, grounded in layers of factual error, be "taken into consideration" when debating the legalization of euthanasia.

③ Rhetorical Manipulations

Let us consider the English title assigned to the Foreword (Bioethics, Vol. 35, No. 1, Sep. 2025): "Euthanasia goes beyond the bounds."―Observations of the United Nations Committee on the Rights of Person with Disabilities, 2025.

Although the UN Committee on the Rights of Persons with Disabilities never made the statement "Euthanasia goes beyond the bounds," Mr. A presented a title that leads readers to believe they did. Viewed critically, this can be seen as intentional manipulation by Mr. A to make readers think the UN Committee explicitly asserted that "euthanasia goes beyond the bounds." While Mr. A might have deemed this title "appropriate" to crown the UN Report's content, nowhere in the UN Report does it state anything resembling "euthanasia goes beyond the bounds." In fact, the UN Report does not directly criticize Canada's euthanasia law itself; rather, it expresses strong concerns regarding the government adopting the Quebec Superior Court ruling as-is and passing Bill C-7.

Moreover, according to Mr. A, the phrase "Euthanasia goes beyond the bounds" is a quote from an opinion piece published in the French newspaper La Croix criticizing French euthanasia legislation. If it was originally written in French, why was there a need to translate it into English and juxtapose it directly with the UN Committee Report? Does he assume readers only understand English? Or raises the suspicion that by translating it into English, he engaged in impression manipulation to make it appear as though the UN Committee Report itself declared "Euthanasia goes beyond the bounds." Presumably, linking this "phrase" with the UN Report was an attempt to lend authoritative weight to the slippery slope argument that legalizing euthanasia inevitably leads to deviation.

Aside from the above, there are passages where it is unclear whether the text is a translation or the author's own writing. Perhaps hesitant to present a block composed entirely of translated quotes, the author writes certain parts as though they are facts he personally verified:

There is no recognition that inequality and discrimination are what create and amplify the "suffering" of persons with disabilities; there are only ableist assumptions that disregard the countless support options that would enable persons with disabilities to live dignified lives. It is evident from the government’s own statistics that Canada is failing to address the social determinants of health and well-being. "Medical assistance in dying" is "disproportionately utilized by women with disabilities and persons with disabilities in marginalized situations," and "the number of persons with disabilities being killed is on the rise." The Committee also expressed opposition to Canada's plans to expand euthanasia after 2027 to individuals whose "sole underlying condition is a mental illness" and to mature minors.

In the passage above, quotation marks have been removed from the sentence: It is evident from the government’s own statistics that Canada is failing to address the social determinants of health and well-being. This makes the sentence read as though it were Mr. A's own statement—implying that Mr. A personally reviewed government reports and confirmed this fact. Which specific reports did Mr. A read to arrive at this conclusion? None—because this sentence, too, is a direct quote from the UN document. Why did he remove the quotation marks only for this sentence? Likely because presenting it as a fact he personally verified was an attempt to prove the factual legitimacy of his article.

There are also instances where the content of the UN Report has been altered, whether due to mistranslation or otherwise. Mr. A writes that "The UN Committee on the Rights of Persons with Disabilities is deeply concerned about violations of Article 10 ('Right to life') of the Convention on the Rights of Persons with Disabilities." However, the accurate understanding of the UN Report is that the Committee is "deeply concerned about the enactment of Bill C-7 in 2021, which amended the State party’s Criminal Code [from the perspective of the right to life]." In this manner, Mr. A unilaterally alters and relays the contents of the UN Report.

I have detailed the errors in this Foreword at length above, but I offer one final word. Before parading the UN Report around to declare that we must "take into consideration" how Canada and other nations that have legalized euthanasia are allegedly driving disabled people to their deaths via "euthanasia" laws just like Nazi Germany, shouldn't Mr. A himself "take into consideration" the steps Canada has taken to alleviate barriers to inclusion for persons with disabilities—such as adopting the Accessible Canada Act (2018) and implementing the Disability Inclusion Action Plan?

For Reference: Eligibility Criteria of Canada's Previous Euthanasia Legislation

Criminal Code C-14 (2016) 241.2 (1) A person may consent to have death inflicted on them by means of medical assistance in dying only if they meet all of the following criteria: (a) they are eligible—or, but for any applicable minimum period of residence or waiting period, would be eligible—for health services funded by a government in Canada; (b) they are at least 18 years of age and capable of making decisions with respect to their health; (c) they have a grievous and irremediable medical condition; (d) they have made a voluntary request for medical assistance in dying that, in particular, was not made as a result of external pressure; and (e) they give informed consent to receive medical assistance in dying after having been informed of the means that are available to relieve their suffering, including palliative care.

(2) A person has a grievous and irremediable medical condition only if they meet all of the following criteria: (a) they have a serious and incurable illness, disease or disability; (b) they are in an advanced state of irreversible decline in capability; (c) that illness, disease or disability or that state of decline causes them enduring physical or psychological suffering that is intolerable to them and that cannot be relieved under conditions that they consider acceptable; and (d) their natural death has become reasonably foreseeable, taking into account all of their medical circumstances, without a prognosis necessarily having been made as to the specific length of time that they have remaining.

(Note: Criminal Code Bill C-7 (2021) repealed subsection (2)(d).)

Footnotes: [1] Section 7: Everyone has the right to life, liberty and security of the person and the right not to be deprived thereof except in accordance with the principles of fundamental justice. [2] Section 15 (1): Every individual is equal before and under the law and has the right to the equal protection and equal benefit of the law without discrimination and, in particular, without discrimination based on race, national or ethnic origin, colour, religion, sex, age or mental or physical disability.