Exploring the Right to Die: Debates and Legal Frameworks

1. Introduction

The right to life is enshrined in the international and national laws across the counties. The European Convention on Human Rights (ECHR), Article 2 provides everyone with the right to life. Article 3 of the Universal Declaration of Human Rights provides that ‘everyone has the right to life, liberty and security of person’. The UK Human Rights Act 1998 gives effect to the ECHR rights, which includes Article 2.

There has been an ongoing debate of whether this right should also include the right to die. The ground for the demand of the right to die may be found in medical reasoning. There are people with terminal illness suffering increasing debilitation and may be excruciating pain. In such cases, the debate regarding the right to die arises.

The right to life may mean the right to live with dignity, for which the state must take measures to protect it, including removing obstacles to the enjoyment of this right. However, where a person is not in a condition to enjoy their right to life in the manner desired, there may be constitutional questions. This essay will explore the question of granting the right to die.

Determining the threshold to grant the right to die

Individuals possess human rights solely by the virtue of their humanity. Personal liberty and human dignity form the foundations of these rights. Young (2021) linked this notion with John Locke’s philosophy that human beings are entitled to certain rights arising from their moral nature. She cited John Locke, who stated that these rights are their property in their own ‘person’. Accordingly, Young argues if the a person has the right to decide over their own bodies, including the right to determine their own existence or non-existence. Benator (2011) states that it would interfere a person’s freedom if they are force to die ‘when they think that their lives are still worth living’. At the same time, Benator also states that ‘it is no less a violation of human freedom to force a continuation of life when people’. The question is how to determine the threshold that could validate the demand for right to die or where a person decides to exercise their right to die, if such right was granted. For this, the later paragraphs will analyse the active voluntary euthanasia (AVE) and physician assisted suicide (PAS) for the purpose of this essay.

---

1. Sunstein, Cass R., ‘The right to die’ (1996) 106 Yale LJ 1123.
2. Elizabeth Wicks, ‘The Meaning of ‘Life’: Dignity and the Right to Life in International Human Rights Treaties’ (2012) 12(2) Human Rights Law Review 199-219.
3. Sarah Joseph, ‘Extending the Right to Life Under the International Covenant on Civil and Political Rights: General Comment 36’ (2019) 19(2) Human Rights Law Review 347-368.
4. Sharon Young, ‘Understanding rights in the context of a “right to die” in Sue Westwood (ed.), Regulating the End of Life Death Rights (Taylor & Francis 2021).
5. Ibid

Euthanasia comes from the Greek words su meaning ‘good’ and Thanatos meaning ‘death’. For the purposes of this essay, this essay will discuss active voluntary euthanasia (AVE) and physician assisted suicide (PAS). AVE involves the act of a physician that is intentional and ends a person’s life upon their request. In PAS, the person self-administers a lethal substance prescribed by a physician. Both the AVE and PAS are illegal. In this context, it is argued that making a person continue living that they find it intolerable when they could have the option of getting help to end or assist in ending their life violates their freedom to live or die as they deem fit. The question is whether or how this exercise of autonomy could be achieved.

In regard to the medical sphere, a competent adult has the autonomy to make informed decisions regarding their own medical care. A physician’s respect for this autonomy will include preserving the adult’s right to self-determination and giving them guidance to enable the adult to make an informed, independent and a free choice. In this context, one could see legislative attempts to legalise medically assisted dying. There was the House of Lords, Medical Ethics: Select Committee Report 1994 that was regarding the end-of-life decision-making, including medically assisted dying. Then, there was the Assisted Dying for the Terminally Ill Bill [HL] 2005 that was regarding whether there should be a law permitting assisted dying including a consideration of criminal liability of those assisting the death, patient’s integrity and sanctity, competency, elderly and disabled patients’ position, and abuse of the law. It also considered permitted medically assisted dying as the last resort for terminally ill persons that are suffering unbearably. This bill also considered voluntary euthanasia subject to authorisation if the patient is not physically capable to take their own life with supplied medication. There was the 2013 Margo MacDonald’s bill that considered assisted dying for patients with terminal or life-shortening illnesses. There was the Lord Falconer’s Assisted Dying bill [HL] 2014-15 that considered assisted suicide regarding mentally competent adults with less than 6 months to live.

---

1. David Benatar, ‘A legal right to die: responding to slippery slope and abuse arguments’ (2011) 18(5) Current Oncology 206-207.
2. Ibid.
3. Emily Jackson, Medical law: text, cases, and materials (Oxford University Press 2013), 906.
4. LucDeliens and Gerrit Van der Wal, ‘The euthanasia law in Belgium and the Netherlands’ (2003)362(9391) The Lancet 1239-1240.
5. J. Pereira, ‘Legalizing euthanasia or assisted suicide: the illusion of safeguards and controls’ (2011) 18(2) CurrOncol e38–e45.
6. Ibid
7. David Benatar, ‘A legal right to die: responding to slippery slope and abuse arguments’ (2011) 18(5) Current Oncology 206-207.
8. Andreas Fontalis, Efthymia Prousali and Kunal Kulkarni, ‘Euthanasia and assisted dying: what is the current position and what are the key arguments informing the debate?’ (2018) 111(11) Journal of the Royal Society of Medicine 407-413.
9. House of Lords, ‘Medical Ethics: Select Committee Report’ HL Deb 09 May 1994 Vol 554 cc 1344-412 accessed 3 January 2022 .

Irrespective of the legislative attempts through the bills and reports mentioned above, the right to die arguments even through medical assistance have not found legal validation. Thus, it will be a crime for a medical professional if they deliberately end the life of their patients irrespective of their motive and the patients’ consent. The Suicide Act 1961 may also be applicable here. This Act makes it illegal to “[a]id, abets, counsel or procure the suicide of another or assists an attempt of another to commit suicide”. Arguments that do not favour PAS or AVE may either be a slippery slope argument or an argument regarding the danger of abuse. In regard to the slippery slope argument, it is argued that if an act is allowed, then it would permit further such actions that may be morally wrong.

Hartling (2006) raises the question of regulating the right to die when the argument of respecting one’s sanctity of life and their dignity is considered. In cases where there is no clear laws on the decisions to end life, there may be consideration for indirect euthanasia, where through medication to reduce pain it also quickens the dying process. Hartling argues that the question of autonomy in regard to decisions to end life is illusionary if seen from a philosophical and ethical point of view. Hartling states that it would be questionable to grant a person to the possibility of euthanasia given that a person may not be purely autonomous, and if legalised, a patient would be under pressure to make a decision which do contradicts the freedom of choice associated with the decision making. Hartling argues that it would be irrational to think that a choice to reduce suffering and improve life could be through annihilation. Thus, Hartling argues that the choice or the decision making can hardly be free. However, Boyle (1980) argues that an indirect form of euthanasia could be justified employing the ‘Doctrine of Double Effect ‘, which proposes that if a moral act produces a morally bad side effect, the act is ethically correct if the side effect was not intended and was even foreseeable. Thus, it might be argued that the intention of a treatment was not to end the life of a patient, but to make them more comfortable.

---

1. Select Committee on the Assisted Dying for the Terminally Ill Bill, ‘Assisted Dying for the Terminally Ill Bill [HL] 2005’ (Authority of the House of Lords) accessed 3 January 2022
2. Ibid.
3. House of Lords, ‘Assisted Dying Bill [HL]’ (2014) accessed 3 January 2022 .
4. Care Not Killing Alliance, ‘Lord Falconer’s Assisted Dying Bill’ accessed 4 January 2022
5. Emily Jackson, Medical law: text, cases, and materials (Oxford University Press 2013) 907.
6. Hartling OJ, ‘Euthanasia: the illusion of autonomy’ (2006) Med Law.;25:189–199.
7. Ibid.

In this context, it may be noted that rights and dignity are perceived as the basis for human rights. Donnelly (2003) argues that rights should be enjoyed “simply because one is a human being. Young argues that human dignity may offer a basis for the existence of human rights. This may offer a reasonable explanation to base the arguments proposing the right to die. Such arguments were found in the case of Pretty. Pretty was diagnosed with motor neurone disease, and she suffered for several years making it impossible for her to easily move or communicate. Although she was mentally normal, because of her illness, she was looked after by her husband and the nurses round the clock. She argued that the state breached her Convention rights, particularly Article 2, which she argued included her right to die. She also argued that her husband should not be prosecuted in case he assisted her suicide. She also based her argument on Article 3 that concerns prohibition of inhuman and degrading treatment, Article 8 that concerns the right to respect for private life, Article 9 that concerns the freedom of consciences and Article 14 that concerns prohibition of discrimination. The UK courts (the Director of Public Prosecutions, the Divisional Court and the House of Lord) dismissed her application based on Article 2(1) of the Suicide Act, 1961 which criminalises assisting another to commit suicide. The ECtHR ruled that there were no violations of any of the ECHR provisions since Article 2 does not provide for the right to die. It also ruled that prohibiting Pretty from exercising her choice to avoid an undignified and distressing end of her life would be interference under Article 8(1), which is however, justified under Article 8(2) that provides for interference necessary in a democratic society to protect rights of others.

1. Ibid.
2. Joseph M Boyle Jr, ‘Toward understanding the principle of double effect’ (1980) 90(4) Ethics 527-538.
3. Ibid
4. George Kateb, Human Dignity (Harvard University Press 2014); Michael Rosen, Dignity: Its History and Meaning (Harvard University Press 2018).
5. Jack Donnelly, Universal human rights in theory and practice (Cornell University Press 2003) 10.
6. Sharon Young, ‘Understanding rights in the context of a “right to die” in Sue Westwood (ed.), Regulating the End of Life Death Rights (Taylor & Francis 2021).
7. R (on the application of Pretty) v Director of Public Prosecutions [2001] UKHL 61; Pretty v United Kingdom (2002) 35 EHHR I.
8. Ibid.

The ruling in Pretty seems to have followed a slippery slope argument. To reiterate Boyle, in the absence of a clear euthanasia legislation, there could be arbitrary, non-voluntary and involuntary euthanasia. This view is supported by Rubin (2011), Lanham (2002), and Ackermann (2000). A conservative view of euthanasia is it must voluntary to be ethical. It is not voluntary regarding unconscious individuals or those who are not able to make a meaningful choice between living and dying and a person makes the decision on their behalf. It is also not voluntary when person who dies chose life but instead went through euthanasia at the request of another person. In regard, Rubin (2011), Lanham (2002), and Ackermann (2000) argue that this slippery slope argument could give rise to out of control euthanasia or PAS. But then, how are some countries able to accept active euthanasia and PAS? Active euthanasia is legal in the Netherlands, Colombia Belgium, and Luxembourg. PAS is legal in Switzerland, Germany, Canada, Japan and in the US’ states of Washington, Oregon, Vermont, Montana, and California. The Netherlands has permitted euthanasia and PAS. The patients have to receive every available type of palliative care. Euthanasia is legalised in Luxembourg and Uruguay for terminally ill patients. At the same time, active euthanasia is illegal in Australia, the United Kingdom, Austria, Denmark, China, and France among other countries.

The non-uniform position across the countries represent valid rationales behind the arguments that either favour or oppose the claim of the right to die. However, those who opposes the argument regarding right to die based on the possibility of abuse should also note that abuse could occurred notwithstanding the prohibition of AVE of PAS. This view is applicable to the ruling on Pretty, which based its rationale on the concept of vulnerability and stated that there was a clear chance of abuse despite any safeguards and hence, a blanket ban on assisted suicide. Irrespective of the ban, for instance in the Netherland before it legalised voluntary euthanasia, there was cases of euthanasia. In 2005, there were reportedly 2410 physician-assisted suicide or active and voluntary euthanasia. Such abuse cases seem to undermine the arguments against or prohibition of AVE or PAS. Because it may often be the question of a patient’s autonomy considering their sense of futility regarding a terminal illness and associated suffering. In Nicklinson v Ministry of Justice, Tony Nicklinson suffered a severe stroke. He became paralysed from the neck down. He described his life then as a ‘living nightmare’. He applied to the High Court for a declaration that it would be legal for a doctor to assist in his suicide and that the criminalisation of assisted suicide contradicts his Article 8 ECHR rights. The High Court refused his application. He refused all food and died of pneumonia. Lord Dyson of the Supreme Court held that sanctity of life cannot give way to personal autonomy or dignity. The judgement might have failed to recognise that it was not merely the pain that Nicklinson found his life not worth living. Rather, it might have been the prospect of continuing to the ‘living nightmare’ for the rest of his life that he found worse than dying. If only he was allowed an assisted ending of his life, he would have endured further suffering by avoiding food and suffering pneumonia that eventually took his life.

1. Pretty v United Kingdom 2346/02 [2002] ECHR 427 ECtHR
2. Joseph M Boyle Jr, ‘Toward understanding the principle of double effect’ (1980) 90(4) Ethics 527-538
3. Rubin EB, ‘Ethical aspects of disordered states of consciousness’ (2011) 29(4) Bernat JL Neurol Clin 1055-71; Barry RL. Lanham, The Sanctity of Human Life and Its Protection (University Press of America 2002); Ackermann RJ, ‘Withholding and withdrawing life-sustaining treatment’ (2000) 62(7) Am Fam Physician 1555-60, 1562, 1564.
4. Rocco Salvatore Calabrò, et al., ‘The right to die in chronic disorders of consciousness: can we avoid the slippery slope argument?’ (2016) 13(11-12) Innovations in clinical neuroscience 12.
5. David Benatar, ‘A legal right to die: responding to slippery slope and abuse arguments’ (2011) 18(5) Current Oncology 206-207.

The experience of the ‘living nightmare’ raises the question on the validity of the arguments against the right to die. In this context, the question is how the sanctity of life argument or the argument for potential abuse of a legislation that may allow PAS or AVE would reduce the suffering of those experiencing the ‘living nightmare’. In the case of Regina, Lord Steyn ruled that the jury must consider factors regarding the state of mind to determine a case of murder. In the case of Cox, it was ruled that it is not lawful to administer drugs where the main purpose is to hasten death. In the case of Moloney, if a person foresees the probability of a consequence, it establishes the necessary intent. These cases show that any act that shows an intent to hasten death would be a criminal offence. On the other hand, in Moor, the jury acquitted Dr. Moor who helped patients die painlessly.

1. R (on the application of Pretty) v Director of Public Prosecutions [2001] UKHL 61; Pretty v United Kingdom (2002) 35 EHHR I.
2. J. Pereira, ‘Legalizing euthanasia or assisted suicide: the illusion of safeguards and controls’ (2011) 18(2) Curr Oncol. e38–e45.
3. Alan J. Sinclair, John E. Morley and Bruno Vellas, Pathy's Principles and Practice of Geriatric Medicine (John Wiley & Sons 2012).
4. Nicklinson v Ministry of Justice [2013] EWCA Civ 961.
5. Ibid.
6. Regina v. Secretary of State for the Home Department (Appellant) ex parte Sivakumar (FC) (Respondent), [2003] UKHL 14.
7. R v Cox (1992) 12 BMLR 38.

Considering this set of cases and the arguments so far, it would be a justifiable question to determine how the argument against the right to die would be justifiable in case a patient is in a vegetative state, or in case a person who is experiencing a ‘living nightmare’ but is mentally capable of self-determination about their life. In Pretty, the ECtHR gave a blanket ruling against the right to die irrespective of the experience of a life without dignity and with stress. The rationale was to protect weak and vulnerable people who cannot take informed ending-life decisions. This is especially applicable to those who lack mental capacity. Support is found in the 16 public interest factors favouring prosecution based on the argument that the medical professionals who assisted ending life decisions were acting in their capacity. These viewpoints are relevant with the slippery slope and abuse of legislation arguments mentioned above. Bullock (2015), Goldman and Schafer (2011), and Kopelman Ville (2001) elaborated on these aspects arguing that assisted dying is based on the best interests and consent of the patient, which raises the question of determining consent and mental capacity to give the consent and subsequently the question of autonomy where the patient may be under stress and compulsion to make the decisions. This raises the possibility of the abuse of the patients’ autonomy. The 2006 report on Assisted Dying for the Terminally Ill Bill recognised these aspects by stating out the challenges regarding competency issues given the multiple neurological conditions of patients, which may include severe cognitive impairments despite the patients appearing normal. Hence, this report stated the chances of slippery slope ending life decisions taken by medical professionals. However, Johnson (2011) argued that the controversy regarding the ending life-sustaining medical treatment particularly involving those in minimally conscious states is based on the assumptions regarding moral significance of consciousness and the value of life. He argued that surrogates should be permitted to make withdraw life-sustaining medical treatment decision on behalf of patients in minimally conscious states.

1. R v Moloney [1985] 1 AC 905.
2. R v Moor [1999] Crim LR 2000 Jul 568-90.
3. R (on the application of Pretty) v Director of Public Prosecutions [2001] UKHL 61; Pretty v United Kingdom (2002) 35 EHHR I.
4. Emily Jackson and John Keown, Debating Euthanasia (Hart Publishing Ltd 2012).
5. E.C. Bullock, ‘Assisted Dying and the Proper Role of Patient Autonomy’ in Cholbi M. and Varelius J. (eds.), New Directions in the Ethics of Assisted Suicide and Euthanasia. International Library of Ethics, Law, and the New Medicine (Springer 2015).
6. Lee Goldman and Andrew I. Schafer, Goldman's cecil medicine E-book (Elsevier Health Sciences 2011).
7. Select Committee on Assisted Dying for the Terminally Ill Bill, ‘First Report 2005 CHAPTER 4: Practical issues’ accessed 4 January 2022

The discussion so far has presented the question of the exercise of autonomy and living with dignity on one hand and the sanctity of life on the other hand. Regarding the former, the challenge is in clearly determining whether a patient has free autonomy absent any pressure and stress. This relates to the arguments presented by Pretty in Pretty, Hartling (2006), and Boyle (1980). The latter is concerning the sanctity of life based on the possible abuse of legislation and the slippery slope arguments. This related to the arguments presented by Rubin (2011), Lanham (2002), and Ackermann (2000) and the case rulings in Pretty and Nicklinson v Ministry of Justice. However, the analysis of the two sides of the arguments indicate that a blanket ban on ending-life decisions may not be justified. This rationale is that the right to life indicates a life to live with dignity or living and not experiencing a ‘living nightmare’. The challenge so far seems to be an inability on the part of the court and the legislature to formulate a clear guideline governing ending-life decisions. However, special consideration could be given to the suggestions by the earlier discussed bills and reports; the experiences of patients, particularly who still have the mental capacity to self-determine their life discourses; and experiences of other countries that have legalised assisted endling-life decisions. For example, one could follow Luxembourg that allowed endling life decisions involving patients without decision-making capacity and who have made advance directives; and decriminalised medical professionals where the patients, who were in grave and incurable conditions, have repeatedly sought for the procedure. One could also follow the

Netherlands that allowed medically assisted euthanasia to patients suffering unbearably and who voluntarily and persistently sought the procedure. Further, Belgium also allows physician-assisted endling life decisions involving patient suffering irreversible unconsciousness and who have given advances.

1. LSM Johnson, ‘The right to die in the minimally conscious state’ (2011) 37(3) Journal of Medical 175-178.
2. R (on the application of Pretty) v Director of Public Prosecutions [2001] UKHL 61; Pretty v United Kingdom (2002) 35 EHHR I.
3. Ibid
4. Nicklinson v Ministry of Justice [2013] EWCA Civ 961.
5. Raymond J. Devettere, Practical Decision Making in Health Care Ethics: Cases, Concepts, and the Virtue of Prudence (Georgetown University Press 2016) 417-418.
6. Ibid.

Conclusion

This essay has found that it is mostly the slippery slope argument and the argument regarding the abuse of legislation that has denied the right to die. These arguments seem to show an inability to consider the terminal pain of suffering or more important the living experiences that Tony Nicklinson or Pretty suffered. The ‘living nightmare’ of continuing to live a life without dignity or the ability to enjoy their life seems to be worse than dying. At the same time, there is also a real fear of abuse of law or the chances of ending-life decisions that are made under pressure violating the sanctity of life.

The overall understanding from the discussion in this essay is that there is a possibility of laying down a strict norm that could justify endling-life decisions. Deriving from the cases laws, the bills, report and rationales of jurisdictions that allow such decision, this essay will conclude with a recommended assisted procedure, particularly for patients with mental capacity, which requires: i) unbearable suffering that is grave and an incurable condition; ii) advance directives regarding the procedure; iii) voluntarily and persistent application for the procedure.

Legislation

• European Convention on Human Rights
• The Suicide Act, 1961

Cases

• Nicklinson v Ministry of Justice[2013] EWCA Civ 961.
• R (on the application of Pretty) v Director of Public Prosecutions [2001] UKHL 61; (2002) 35 EHHR I; 2346/02 [2002] ECHR 427 ECtHR
• Regina v. Secretary of State for the Home Department (Appellant) ex parte Sivakumar (FC) (Respondent), [2003] UKHL 14
• R v Cox (1992) 12 BMLR 38.
• R v Moloney [1985] 1 AC 905.
• R v Moor [1999] Crim LR 2000 Jul 568-90.

Books

• Bullock EC, ‘Assisted Dying and the Proper Role of Patient Autonomy’ in Cholbi M. and Varelius J. (eds.), New Directions in the Ethics of Assisted Suicide and Euthanasia. International Library of Ethics, Law, and the New Medicine (Springer 2015)
• Devettere RJ, Practical Decision Making in Health Care Ethics: Cases, Concepts, and the Virtue of Prudence (Georgetown University Press 2016)
• Donnelly J, Universal human rights in theory and practice (Cornell University Press 2003)
• Goldman L and Andrew I. Schafer, Goldman's cecil medicine E-book (Elsevier Health Sciences 2011)
• Jackson E, Medical law: text, cases, and materials (Oxford University Press 2013)
• Kateb G, Human Dignity (Harvard University Press 2014); Michael Rosen, Dignity: Its History and Meaning (Harvard University Press 2018)
• Lanham BRL, The Sanctity of Human Life and Its Protection (University Press of America 2002);
• Sinclair AJ, John E. Morley and Bruno Vellas, Pathy's Principles and Practice of Geriatric Medicine (John Wiley & Sons 2012).
• Young S, ‘Understanding rights in the context of a “right to die” in Sue Westwood (ed.), Regulating the End of Life Death Rights (Taylor & Francis 2021).

Journals

• Ackermann RJ, ‘Withholding and withdrawing life-sustaining treatment’ (2000) 62(7) Am Fam Physician 1555-60, 1562, 1564
• Benatar D, ‘A legal right to die: responding to slippery slope and abuse arguments’ (2011) 18(5) Current Oncology 206-207
• Boyle JM, ‘Toward understanding the principle of double effect’ (1980) 90(4) Ethics 527-538.
• Cass R S, ‘The right to die’ (1996) 106 Yale LJ 1123.
• Calabrò RS, et al., ‘The right to die in chronic disorders of consciousness: can we avoid the slippery slope argument?’ (2016) 13(11-12) Innovations in clinical neuroscience 12.
• Deliens L and Gerrit Van der Wal, ‘The euthanasia law in Belgium and the Netherlands’ (2003)362(9391) The Lancet 1239-1240
• Fontalis A, Efthymia Prousali and Kunal Kulkarni, ‘Euthanasia and assisted dying: what is the current position and what are the key arguments informing the debate?’ (2018) 111(11) Journal of the Royal Society of Medicine 407-413.
• Hartling OJ, ‘Euthanasia: the illusion of autonomy’ (2006) Med Law.;25:189–199
• Johnson LSM, ‘The right to die in the minimally conscious state’ (2011) 37(3) Journal of Medical 175-178
• Joseph S, ‘Extending the Right to Life Under the International Covenant on Civil and Political Rights: General Comment 36’ (2019) 19(2) Human Rights Law Review 347-368.
• Pereira J, ‘Legalizing euthanasia or assisted suicide: the illusion of safeguards and controls’ (2011) 18(2) CurrOncol e38–e45.
• Rubin EB, ‘Ethical aspects of disordered states of consciousness’ (2011) 29(4) Bernat JL Neurol Clin 1055-71
• Wicks E, ‘The Meaning of ‘Life’: Dignity and the Right to Life in International Human Rights Treaties’ (2012) 12(2) Human Rights Law Review 199-219.

Reports

• Care Not Killing Alliance, ‘Lord Falconer’s Assisted Dying Bill’ accessed 4 January 2022
• House of Lords, ‘Assisted Dying Bill [HL]’ (2014) accessed 3 January 2022 .
• House of Lords, ‘Medical Ethics: Select Committee Report’ HL Deb 09 May 1994 Vol 554 cc 1344-412 accessed 3 January 2022 .
• Select Committee on the Assisted Dying for the Terminally Ill Bill, ‘Assisted Dying for the Terminally Ill Bill [HL] 2005’ (Authority of the House of Lords) accessed 3 January 2022
• Select Committee on Assisted Dying for the Terminally Ill Bill, ‘First Report 2005 CHAPTER 4: Practical issues’ accessed 4 January 2022

Looking for further insights on Exploring the Lived Experiences of Rough Sleeping? Click here.