Abstract
Aims and methodThe legal provisions concerning the admission to hospital, holding powers and compulsory treatment of the mentally ill in Germany are illustrated. The essential legal concepts are compared to the situation in Great Britain.ResultsWhereas British law gives key powers to multi-professional decision-making and relatives, German law requests formal court decisions even in routine cases. This reflects a different understanding of individual rights and their protection. German mental health law is motivated by the experiences of the totalitarian national socialist regime. It tries to protect patients' rights by restricting physicians', hospitals' and family members' Influence. British law, on the other hand, assumes that experts as well as family members act benevolently in the patient's Interest, prefers less formal mechanisms and expresses more trust in professional ethics.ConclusionFurther research is desirable to analyse the situations in other countries and to determine which of these approaches is the most adequate from the point of view of the mentally ill. This is even more important in view of further European integration which will undoubtedly touch these questions and accelerate a convergence in medico-legal issues.
Highlights
Whereas the med ical and scientific standards in Great Britain and Germany are comparable, fundamental differ ences exist in medico-legal concepts and the psychiatric practice as far as sectioning, forced treatment and guardianship issues are con cerned
This has recently been highlighted by several High Court decisions
Public law is the domain of the 16 Federal States, each of which has a different sectioning law (Unterbringungsgesetz)
Summary
Comorbidity was common, but more patients improved following the intervention (effect size=0.64-l .34). The 25% therapy drop-out rate was comparable with previously reported rates. Four out of five patients who dropped out had Cluster B personality disorders. The two cohorts showed similar baseline characteristics, but the second cohort showed
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