Journal List > J Korean Neuropsychiatr Assoc > v.58(4) > 1138958

Joe and Jang: Comparison of Mental Health Act about Involuntary Admission among 4 East Asian Countries



The aim of this study was to explore trends associated with the amendment of The Mental Health Welfare Act by comparing involuntary admission processes in Asian countries.


We obtained copies of the Mental Health Acts for four East Asian countries ??Korea, Japan, Singapore, and Taiwan (China). We then analyzed the contents of the acts including their definitions of mentally ill patients, the types of hospitalization, and the procedures for involuntary admission.


The Japanese provision for involuntary admission was the prototype used for the Korean system prior to the total revision of the Korean system in 2016. Regardless, Korea and Japan still regard family members as pivotal in deciding on involuntary admission. Taiwan and Singapore acts are characterized by the involvement of government or government-designated medical practitioners, not caregivers, in the hospitalization process. In Taiwan, involuntary admission is decided by a judgment of a review committee and is a task of the government. In Singapore, the opinions of experts are considered when making the initial decision on involuntary hospitalization, whereas a judicial decision is essential for extension of that hospitalization.


Despite cultural and historical similarities, the systems of involuntary admission were considerably different across the countries. We observed a reduction in the role of family guardians and an increase in the use of more objective screening processes. All four countries were in the process of applying those recommendations from international organizations that were in accordance with their society/culture. There may be a need to partially amend The Mental Health Welfare Act in Korea in order to protect the human rights of psychiatric patients while maintaining a stable therapeutic environment.


Special thanks for the researchers from foreign countries as follows ; Dr. Chiyo Fujii (National Center of Neurology and Psychiatry, Japan), Dr. Kevin Chien-Chang Wu (National Taiwan University Hospital, Taiwan), Dr. Daniel Fung (Institute of Mental Health, Singapore).


Conflicts of Interest The authors have no financial conflicts of interest.


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