Law and Policy in Healthcare Decision-Making: A Comparative Analysis of Singapore and Japan

This study provides a comparative legal and policy analysis of healthcare decision-making frameworks in Singapore and Japan, focusing on informed consent, mental capacity, and advance directives. Singapore’s common law-based system emphasizes individual autonomy through mechanisms such as the Lasting Power of Attorney (LPA), providing clear legal safeguards and structured planning for incapacity, though clinical practice may still reflect relational decision-making. By contrast, Japan’s civil law-influenced and community-oriented framework relies more heavily on familial involvement and physician discretion, reflecting culturally embedded relational values. The comparison highlights trade-offs between legal certainty and cultural appropriateness and identifies opportunities for mutual policy learning. Japan could strengthen patient autonomy by adopting elements of Singapore’s LPA framework, while Singapore could benefit from Japan’s community-based care practices. Overall, the study emphasizes the importance