Penney Lewis, LLM, Reader in Law at the School of Law and Centre of Medical Ethics at Kings College, stated in a Spring 2007 Journal of Law, Medicine & Ethics: article titled "The Empirical Slippery Slope from Voluntary to Non-Voluntary Euthanasia":

“Most critics rely predominantly on Dutch evidence of cases of ‘termination of life without an explicit request’ as evidence for the slide from voluntary euthanasia to non-voluntary euthanasia. According to the three national surveys of ‘medical behaviour which shortens life’ in the Netherlands, the cases in the ‘termination of life without an explicit request’ category represent less than one percent of all deaths…

There is no evidence demonstrating that the Netherlands has a greater rate of non-voluntary or involuntary euthanasia than other Western countries. Indeed, there is a significant amount of evidence demonstrating the prevalence of both voluntary and nonvoluntary active euthanasia in various jurisdictions in which euthanasia has not been legalized, looking at criminal prosecutions, admissions by doctors and anonymous surveys of medical professionals.”

Spring 2007