any problems had been mostly denied by officials of the tbs-clinics themselves. the center of attention became a highly renowned tbs clinic, dr. s. van mesdagkliniek in the city of groningen. events that took place there, by the end of the 1990s and the first years of the 21st century, provoked the second reason for controversy. concern rose about claims of unprofessional behavior by staff working in tbs clinics, and the dr. s. van mesdagkliniek developed a poor reputation over these problems. this tbs clinic has been plagued with unprofessional and even criminal acts by its staff since 1999. during that year, the clinic came under investigation by dutch police after rumors about female staffmembers committing sexual offenses against convicts emerged. five such cases were discovered during the investigation, and also numerous cases of drug-abuse, smuggling and trading of contraband such as alcohol, mobile phones, pornographic material, and hard drugs. it became apparent that staff members did not have the required education, had not been informed about rules and regulations, disregarded legal procedures, gave false testimonies, tampered with evidence, uttered false accusations against convicts, and intimidated colleagues. at least one psychiatrist, employed as such by the clinic, proved to be not qualified, and treatment of convicts was in many cases simply non-existent. these problems had been known for long by the management but were kept hidden. after public outcry about this situation, management was replaced and all of the nine (at the time) tbs clinics in the netherlands were subjected to investigation. six of them proved to be below the required legal standards. however, problems did not end there. in spite of many measures taken by the government, convicts still were released without proper treatment. as a consequence, numerous crimes were committed by convicts that were regarded as treated by tbs clinics. also, sexual offenses against convicts by staff members and smuggling of contraband did not cease in several tbs clinics. in 2006, the dutch government formed a committee to investigate the tbs system. some problems, however not the worst, were recognized and countermeasures were implemented. one of the known actual results is that fewer convicts escape during temporary release. controversy regarding the, often praised, dutch tbs system continued. in 2005, a staff member working in the dr. s. van mesdagkliniek was caught smuggling liquor to convicts suffering from alcohol-related problems. in 2007, a female staff member committed sexual offenses against a convict, and had smuggled contraband. she was sentenced to three months in prison in 2009. that same year, investigation proved convicts still had ample access to illicit drugs and four inmates from the dr. s. van mesdagkliniek were arrested for possession of child pornography. many crimes committed by released convicts treated in tbs clinics escape statistics because the crimes were committed in other countries, or because they differ from the crime the convict was originally convicted for (many convicts released from tbs clinics find their way in illegal drug trade and related crimes). because there seems to be no acceptable alternative available, political support for the much troubled tbs system remains, in spite of the controversy. russia further information: mental health in russia individuals in russia can be involuntarily admitted by psychiatrists directly with an appeal process. new zealand the mental health (compulsory assessment and treatment) act 1992, replaced the previous act, enacted in 1969. although there were several reasons to replace the previous act, one key aspect was the lack of review, as once the reception order had been made by a district court judge and two doctors, that the proposed patient be taken to hospital: "subject to the provisions of this act, every reception order, whether made before or after the commencement of this act, shall continue in force until the patient is discharged." (mha 1969 s28(2)) despite the deinstitutionalization that began in new zealand during the 1960s, as in many other western countries, many patients stayed at the psychiatric hospital for years, as the original reception order remained in force. another reason to review the former act was that patients appeared at the district court (formerly the magistrates court until 1980) - which hears all but the most serious criminal cases. the present act emphasises that mental health hearings be heard at the family court instead, to remove any implication that the patient is being detained in hospital due to a criminal act. it does, however, provide that mental health hearings may take place at the district court, if there is no other suitable alternative. often the family court will sit at the mental health inpatient unit. there are multiple checks and balances built into the present committal procedures. as in the united kingdom, the process is generally known as "sectioning". section 8a provides that any person, aged 18 or over, who has seen the proposed patient within the last 72 hours, may apply to the director of area mental health services (damhs), to have that person seen by a psychiatrist, against their wishes. the person must be a danger to themselves or others, or be unable to care for themselves. section 8b requires that the person be seen by a doctor, preferably their own general practitioner, to give their opinion as to whether the applicant is correct in their statements about the proposed patient's behaviour. if the doctor is satisfied, this paperwork is signed, and the process continues to section 9 where duly authorised officers (daos) - operating as agents of the damhs, have the power to detain the person for six hours, and during that time, they have the power to transport the proposed patient to the psychiatrist. this is usually at a hospital, but the patient may be seen at a police station, depending on the circumstances. if the proposed patient refuses to accompany them, the police will assist under the memorandum of understanding between the ministry of health and the new zealand police. under s10 they are formally interviewed by the psychiatrist, and if they are to be admitted, a s11 is issued that detains the patient for assessment and treatment at an inpatient mental health unit, for up to five days. following this, a s12 review is held, and if necessary the patient can be held under s13 for fourteen days. at the end of this time, the psychiatrist must apply for a court hearing as to whether the patient can be treated compulsorily for any longer. section 14(4) gives up to fourteen days for the hearing to occur. the detention sections (11, 13, & 14(4)) can be done in the outpatient setting, but in practice, most compulsory patients are detained at a hospital. two compulsory treatment orders are available. section 29 is a community treatment order, and the act states that this should be applied for. the patient can only be recalled to hospital twice for two fourteen-day periods in the six months that it lasts. if a community order is not suitable (for example, due to the risk posed by the patient to themselves or others), a s30 inpatient treatment order can be applied for, where the patient is either in hospital, or on leave from hospital. in either case, two health professionals must apply to the family court - the psychiatrist, backed by a second health professional, usually a registered nurse, sometimes a social worker. people who have committed a crime while mentally unwell are subject to the criminal procedure (mentally impaired persons) act 2003, although the mental health act also refers to their care. if taken into custody, it is a matter for the court as to whether they will go to prison and have their mental health issues treated whilst imprisoned, or whether they are "insane" in the legal sense, in which case they are detained at a forensic mental health unit. these are located at auckland, hamilton, wellington, christchurch, and dunedin. the acts described provide also for the transfer of patients between prisons and forensic mental health units, and the reasons for doing this. new zealand has found that closing its large country psychiatric hospitals and replacing them with small inpatient units, and a community care model, does not always mean better care. while many people were released who were able to adapt to, and become part of, their communities, some patients were unable to adapt. the current system is not set up for people who require long term closely supervised mental health care. singapore the mental health (care and treatment) act was passed in 2008 to regulate the involuntary detention of a person in a psychiatric institution for the treatment of a mental disorder, or in the interest of the health and safety of the person or the persons around him. switzerland switzerland has a high proportion of involuntary commitments (german: zwangzulassung, french: placement forcé) compared to other european countries. almost 25% of psychiatric patients were admitted involuntarily according to a 2009 study. the conditions and procedure of involuntary commitments are regulated by articles 426 to 439 of the swiss civil code. united kingdom in the united kingdom, the process known in the united states as involuntary commitment is informally known as "detaining" or "sectioning," using various sections of the mental health act 1983 (covering england and wales), the mental health (northern ireland) order 1986 and the mental health (care and treatment) (scotland) act 2003 that provide its legal basis. in england and wales, approved mental health professionals have a lead role in coordinating mental health act assessments, which they conduct in cooperation with usually two medical practitioners. under the mental health act, detention is determined by utility and purpose. mentally ill individuals may be detained under section 2 for a period of assessment lasting up to 28 days or section 3 for a period of treatment lasting up to 6 months (though this period can be renewed). patients already on a ward may be detained under section 5(2) for up to 72 hours for the purposes of allowing an assessment to take place for section 2 or 3. separate sections deal with mentally ill criminal offenders. in all cases detention needs to be justified on the basis that the person has a mental disorder and poses a risk of harm to his/her own health, safety, or the safety of others (as determined by the 'approved' mental health professional(s)). a section 3 detention can be applied for by the person's nearest relative or, if the nearest relative agrees, by an approved mental health professional (amhp). more specifically, according to article 11 of the mental health act the amhp can make an application that a person be detained for treatment under section 3 only if the amhp has consulted the person who appears to be the patient's nearest relative (unless it is not reasonably practicable or would cause unreasonable delay) and if the nearest relative has not told the amhp or the lssa that they object. under the amended mental health act 2007, which came into force in november 2008 to be detained under section 3 for treatment, appropriate treatment must be available in the place of detention. supervised community treatment orders signifies that people can be discharged to the community on a conditional basis, remaining liable to recall to hospital if they break the conditions of the community treatment order. in 2020, as part of the response to covid-19, parliament passed the coronavirus act 2020 which amends the mental health act to allow for sectioning with the approval of only one medical practitioner. united states state law governs involuntary commitment, and procedures vary from state to state. in some jurisdictions, laws regarding the commitment of juveniles may vary, with what is the de facto involuntary commitment of a juvenile perhaps de jure defined as "voluntary" if his parents agree, though he may still have a right to protest and attempt to get released. however, there is a body of case law governing the civil commitment of individuals under the fourteenth amendment through supreme court rulings beginning in 1975 with the ruling that involuntary hospitalization and/or treatment violates an individual's civil rights in o'connor v. donaldson. this ruling forced individual states to change their statutes. for example, the individual must exhibit behavior that poses a danger to himself or others in order to be held, the hold must be for evaluation only,