The term euthanasia in the earlier sense of supporting someone as they died, was used for the first time by Francis Bacon . In his work, Euthanasia medica , he chose this ancient Greek word and, in doing so, distinguished between euthanasia interior , the preparation of the soul for death, and euthanasia exterior , which was intended to make the end of life easier and painless, in exceptional circumstances by shortening life. That the ancient meaning of an easy death came to the fore again in the early modern period can be seen from its definition in the 18th century Zedlers Universallexikon :
The argument of the Sanctity of Life is reflected here. Deep consideration was given to how government has dispensed with the issue of euthanasia from a historical religious, common law, to the strictly civil decision handed down here. It is to be noted that in order for a writ of certiorari to be granted a constitutional issue must be involved that goes beyond a single individual or a small group of persons. Sanctity of Life not only involves the preservation and giving value to life in all it's forms, and recognizing that diversity has assigned different values for life, but also to rescue life.
According to Wolhandler, (p. 367) it is the nature of the acts performed by the second party that distinguishes between active and passive euthanasia. The courts have held that acts of "omission" (removal of respiratory assistance, hydration, and feeding tubes) are allowable behavior. "Although unplugging a respirator and switching off a dialysis machine are arguably acts of commission, an increasing number of judges and commentators have accepted these acts as permissible passive euthanasia in both voluntary and involuntary settings." Gifford (1993) describes the difference between the two types of euthanasia this way: