due diligence requirements that could be grounds for acquittal, one of them was that a physician should be involved. The judge also remarked that psychiatric suffering can cause unbearable suffering and that the patient does not have to be close to death in order to be eligible for PAD. The first psychiatrist to publish about PAD for PPD was Dr. F. van Ree. In 1982, he wrote a commentary in the Dutch Journal of Psychiatry describing three cases about patients with persistent suicidal ideations. Two of the described patients were eventually ‘allowed’ to commit suicide in a humane manner and one patient eventually recovered after long and involuntary clinical treatment. This dissertation will focus on the topic of irremediability of psychiatric suffering, and although van Ree does not explicitly identify this as an important challenge in the context of PAD, he does however implicitly raise questions that are related to irremediability. For instance, he mentions that psychiatric suffering, just as somatic suffering, can be ‘therapy-resistant’. He also describes that for him performing PAD is only possible if it is preceded by long and intensive treatment. The described cases show that in his view PAD should be regarded as a last resort and his moral justification of allowing patients to die relies implicitly on the irremediability of suffering. In a 1983 article, van Ree addresses irremediability in more detail. He writes that accurate diagnosis and prognosis are challenging in psychiatry and argues that due expertise by psychiatrists is essential during a PADprocedure. Or as he puts it: ‘anyone who has never seen how people can recover from a very deep, vital depression and a seemingly hopeless state, cannot make a sound judgment about assisted suicide.’ He also states that intercollegial consultation should always be sought before PAD is performed. (van Ree, 1983) At the start of the 1990s, the Dutch Psychiatry Association and the Royal Dutch Medical Association issued statements that PAD should be allowed for psychiatric suffering. (van Pinxten, 2012) This viewpoint was confirmed in 1994 by the ruling of the supreme court in the Chabot arrest. This case concerned a 50-year-old woman with a depressed mood who wanted to end her life after both her sons died. Over a period of two months, psychiatrist Chabot met with her to discuss her death wish, he also let her stay in his private guesthouse. She refused psychotherapeutic or psychopharmaceutical treatment. After establishing that she was mentally competent and that there were no treatment options left he assisted in her death by prescribing medication. Although he later stated that he consulted seven colleagues, none of these other psychiatrists examined the woman themselves. Chabot was found guilty of assisted suicide, but no penalty was imposed. In the ruling the judges made clear that, although extreme caution is advised, psychiatric suffering can be a justified ground for PAD. Furthermore, this ruling inspired the practice that in the case of psychiatric PAD, an independent consultation from another expert is mandatory. (Berghmans, 1998; Schoevers, Asmus & Van Tilburg, 1998) INTRODUCTION | 13 1