R v Adams (Bodkin)
A doctor is entitled to do all that is proper and necessary to relieve pain and suffering, even if the measures incidentally shorten life, which is the basis of the doctrine of double effect.
Facts
Dr John Bodkin Adams, a general practitioner in Eastbourne, was charged with the murder of an elderly patient, Mrs Morrell, who had been prescribed large doses of heroin and morphine during her last illness. She had left him property in her will. The prosecution alleged that he had deliberately killed her by administering excessive doses of drugs. He was suspected of involvement in the deaths of other patients.
Legal principle
Devlin J directed the jury that murder is an act or series of acts done by the prisoner which were intended to kill and did in fact kill, and that it does not matter whether death was inevitable or whether her life would have been cut short by weeks or months. However, if the first purpose of medicine, the restoration of health, can no longer be achieved, there is still much for the doctor to do, and he is entitled to do all that is proper and necessary to relieve pain and suffering, even if the measures he takes may incidentally shorten life. Dr Adams was acquitted. The direction is the classic statement of the doctrine of double effect in English law.
Related cases on end of life decisions
- Re A (Children) (Conjoined Twins: Surgical Separation) [2001] Fam 147
- Aintree University Hospitals NHS Foundation Trust v James [2013] UKSC 67, [2014] AC 591
- Airedale NHS Trust v Bland [1993] AC 789
- Alder Hey Children's NHS Foundation Trust v Evans [2018] EWHC 308 (Fam)
- An NHS Trust v Y [2018] UKSC 46, [2019] AC 978
- Re B (A Minor) (Wardship: Medical Treatment) [1981] 1 WLR 1421
- Glass v United Kingdom (2004) 39 EHRR 15
- Great Ormond Street Hospital for Children NHS Foundation Trust v Yates [2017] EWHC 972 (Fam)
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