death is reasonably foreseeable in the sense that she is [almost 80 years
old], in a declining state of health, is virtually immobile, and has an irreversible, incurable and debilitating illness that is causing her incredible suffering. In my view, her death is reasonably foreseeable in that she does not
have long to live given her age and health.
3. The legislative history of medical assistance in dying
 On July 17, 2015, in response to Carter (2015), the federal
Ministers of Health and Justice appointed an External Panel on
Options for a Legislative Response to Carter v. Canada.
 The External Panel held discussions with the intervenors
in Carter (2015) and with relevant medical authorities. It also
conducted a consultation open to all Canadians. On December
15, 2015, the External Panel submitted its final report. The
report identified four categories of how requests for medically
assistance in dying might be authorized, namely, (1) prior judicial authorization; (2) prior authorization by administrative
tribunal; (3) prior authorization by a panel of physicians; or
(4) a decision between individuals and their physicians.
 On December 11, 2015, the Senate and House of Commons struck a Special Joint Committee on Physician-Assisted
Dying to review the External Panel’s final report and to consult
with Canadians, experts and stakeholders, and to make recommendations on the framework of a federal response on physician-assisted dying.
 The special joint committee determined that requiring a
review by either a panel or a judge would create an unnecessary
barrier or impediment to individuals requesting medical assistance
in dying and recommended that the Government of Canada work
with the provinces and territories, and their medical regulatory
bodies to ensure that the process to regulate medical assistance in
dying does not include a prior review and approval process.
 The federal government introduced Bill C-14. The Bill did
not include any requirement for prior judicial or other review
before a physician or nurse practitioner could provide medical
assistance in dying. Instead, the criteria for providing medical
assistance in dying, including the criteria that death has become
reasonably foreseeable, were to be applied by physicians and
nurse practitioners using their professional judgment.
 In introducing Bill C-14, in the House of Commons
Debates, Hon. Jody Wilson-Raybould (Minister of Justice and
Attorney General of Canada, Lib.) stated:
To be clear, the bill does not require that people be dying from a fatal illness
or disease or be terminally ill. Rather, it uses more flexible wording; namely,
that “their natural death has become reasonably foreseeable, taking into
account all of their medical circumstances”. This language was deliberately