Jurisdictions allowing PAD formulated different regulations concerning treatment refusal. In 1994 the Dutch Supreme Court ruled that a patient refusing appropriate treatment does not suffer irremediably, implying that in such a case PAD is not justified. (Berghmans, 1998; Nederlandse Vereniging voor Psychiatrie, 2018; Regionale Toetsingscommissie Euthanasie, 2018) Treatment is defined as appropriate if current medical opinion states that the condition of the patient can be alleviated within a reasonable time period and with a reasonable balance of burdens and benefits. (Nederlandse Vereniging voor Psychiatrie, 2018; Regionale Toetsingscommissie Euthanasie, 2018; Vlaamse Vereniging voor Psychiatrie, 2017) Again, consensus has to be reached through dialogue between the patient and physician for PAD to be justified. (Nederlandse Vereniging voor Psychiatrie, 2018) Several Dutch authors defend this policy throughout the debate. (Berghmans et al., 2013; Rooney et al., 2017) Canada’s assisted dying law is more patient centered, stating that suffering is irremediable when all treatments acceptable to the patient have failed, thus leaving more room for PAD after treatment refusal. (Shaffer et al., 2016; Walker-Renshaw & Finley, 2015) This patient centered view on irremediability, is held by right-to-die societies and is supported by several authors throughout the debate. (Bay, 2017; Downie & Dembo, 2016; Legemaate & Gevers, 1997; Shaffer et al., 2016) Opponents of PAD of PPD argue that the patient centered view on treatment refusal will most likely lead to deaths that could have been prevented by offering treatment. (Appelbaum, 2017, 2018; Yarascavitch, 2017) IRREMEDIABLE PSYCHIATRIC SUFFERING IN THE CONTEXT OF PHYSICIAN ASSISTED DEATH | 61 4