Background The law should help and not hinder patients, their loved ones and healthcare professionals in making advance care plans and end of life decisions.

Aim This paper will review the relevant laws of England and Singapore, and compare their frameworks for end of life decision-making.

Methods The advantages and disadvantages of each regime will be analysed in the context of three groups of patients and their loved ones facing an end of life scenario. The first group is patients who have capacity to make their own treatment decisions and have expressed their wishes. The second is patients who have lost capacity and did not make their wishes known, and the final group is patients who made their preferences known before they lost capacity.

Results There are some similarities between the English and Singapore frameworks but also some striking differences, especially relating to the powers of donees on healthcare decision-making and advance refusals of treatment.

Discussion Given initiatives in advance care planning in England and Singapore, this paper will make recommendations on the elements of an ideal legal framework. England and Singapore do not have legislation pertaining to Physician Orders for Life Sustaining Treatment (POLST) or default surrogates. Are these aspects essential in an ideal legal framework for end of life decision-making?

Conclusion The ideal legal framework is one that empowers patients and their loved ones to plan for their future health care and enables health care professionals to honour those wishes at the appropriate time.