The law's overseeing of administrations of pain-relieving treatment with inevitable life-shortening consequences is of crucial significance in view of the dogmatic approach of English criminal law to active euthanasia. As Lanham states in respect of society's treatment of terminal physical pain:

‘If the euthanasia option is not available, some other method will have to be found. In Britain and Australia that method involves palliative care and the hospice movement. By contrast, in the Netherlands active euthanasia is available and palliative care is poorly developed.’

The recent prosecution in R v Cox made it abundantly clear that causing death in order to relieve a patient of further pain and suffering amounts to murder under current law. By contrast, knowingly shortening life through the administration of pain-killing drugs was recently declared to be lawful by Lord Goff in the House of Lords in Airedale NHS Hospital Trust v Bland.