This is in contrast with the approach taken in the Philippines, where the Constitution provides that the state shall equally protect the life of the mother and the life of the unborn from conception. Similarly, the Charter of Fundamental Rights and Basic Freedoms of the Czech Republic states that human life deserves to be protected before birth. Chances of a universal consensus on this issue are slim due to the difficulty in defining the beginning of life. In Singapore, attempted suicide, abetment of suicide, and abetment of attempted suicide are criminal acts. This applies to physicians who aid patients in ending their lives. Such physicians are unable to claim a defence under section 88 of the Penal Code since they intended to cause the patients' deaths. However, physicians are absolved of liability if patients refuse treatment for terminal illnesses by issuing advance medical directives. Whether the right to life guaranteed by Article 9(1) encompasses a right to die – that is, a right to commit suicide or a right to assisted suicide, usually in the face of a terminal illness – has not been the subject of any Singapore court case. In other jurisdictions, the right to life has generally not been interpreted in this way. In "Gian Kaur v. State of Punjab" (1996) the Indian Supreme Court held that the right to life is a natural right embodied in Article 21 of the Indian Constitution, and since suicide is an unnatural termination or extinction of life it is incompatible and inconsistent with the concept of the right to life. The US Supreme Court has also declined to recognize that choosing death is a right protected by the Constitution. In "Washington v. Glucksberg" (1997), a group of Washington residents asserted that a state law banning assisted suicide was unconstitutional on its face. The majority held that as assisted suicide is not a fundamental liberty interest, it was not protected under the due process clause of the Fourteenth Amendment. Several of the justices seemed persuaded that the availability of palliative care to "alleviate suffering, even to the point of causing unconsciousness and hastening death" outweighed recognizing a new unenumerated "right to commit suicide which itself includes a right to assistance in doing so". Article 9(2) of the Constitution enshrines the right of persons who have been detained to apply to the High Court challenging the legality of their detention. The application is for an order for review of detention, which was formerly called a writ of "habeas corpus". The Court is required to inquire into the complaint, and order the detainee to be produced before the Court and released unless it is satisfied that the detention is lawful.