Australian and Canadian mental health Acts compared

Abstract

OBJECTIVE: The main objective of this paper is to compare the mental health Acts of the eight Australian jurisdictions and the 13 Canadian jurisdictions on three major issues: involuntary admission criteria, treatment authorization/consent and compulsory treatment in the community, in the light of international trends towards patients' rights. METHOD: The legislation was examined against the background of rights instruments such as the Canadian Charter of Rights and Freedoms and the United Nations Convention on the Rights of Persons with Disabilities. RESULTS: It was found that some Canadian involuntary admission criteria require the likelihood of bodily harm whereas all Australian Acts have..