Cultural variations in adoption

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Adoption is an arrangement by which a child whose biological parents are unable to care for it is "adopted" and given the same legal and social status as though he/she were the biological child of the adoptive parents. For example, under a system of adoption, if a parent dies intestate, the adopted child stands in exactly the same position regarding inheritance as a biological child. In adoption systems, the child can also inherit the parent's hereditary rank. Thus, in pre-modern Japan, which had a system of true adoption, a child could inherit the parent's aristocratic title or samuari rank, whereas in England, which only introduced adoption in the 1920s, only a biological child could inherit an aristocratic title. This does not negate the fact that English families often reared, cared for, loved and provided for parentless children. It is only to point out that adoption is a specific legal arrangement within the many kinds of wardship or guardianship or fostering practiced worldwide. While all societies make provision for the rearing of children whose own parents are unavailable to rear them, not all cultures use adoption.

1 Arab
2 Korea
3 Africa
4 India
5 Tikopia
6 References

[edit] Arab

Traditionally in Arab cultures if a child is adopted he or she does not become a “son” or “daughter,” but rather a ward of the adopting caretaker(s). The child’s family name is not changed to that of the adopting parent(s) and his or her “guardians” are publicly known as such. Legally, this is close to other nations' systems for foster care. Other common rules governing adoption in Islamic culture address inheritance, marriage regulations, and the fact that adoptive parents are considered trustees of another individual's child rather than the child's new parents.^[1] In addition, Islamic countries such as Iraq and Malaysia have prohibitions against a child of Muslim parents being adopted by non-Muslim individuals.^[2]^[3]

[edit] Korea

In Korean culture, adoption almost always occurs when another family member (sibling or cousin) gives a male child to the first-born male heir of the family. Adoptions outside the family are rare. This is also why most orphaned Korean children have been exported to countries such as the United States rather than kept in Korea. This is also true to varying degrees in other Asian societies.

[edit] Africa

On the other hand, in many African cultures, children are regularly exchanged among families for the purpose of adoption. By placing a child in another family's home, the birth family seeks to create enduring ties with the family that is now rearing the child. The placing family may receive another child from that family, or from another. Like the reciprocal transfer of brides from one family to another, these adoptive placements are meant to create enduring connections and social solidarity among families and lineages.

[edit] India

There is no uniform adoption law in India; however, this statement could be debated. The Hindu Adoption and Maintenance Act of 1956 allows only Hindus, Sikhs, Jains, and Buddhists to adopt. Muslims, Christians, Jews and Parsees can only become guardians under the Guardians and Wards Act of 1890. Guardianship expires once the child attains the age of 18 years.^[4] For children adopted outside India, guardianship is awarded with the expectation that the child will be quickly adopted by the adopted parents in the country where they legally reside. The Indian government regulates domestic and inter-country adoption of children in India. For current information on adoption of children in India, go to the Central Adoption Resource Authority or C.A.R.A. website on the Internet at http://www.adoptionindia.nic.in/.

[edit] Tikopia

Traditional Tikopia society did not practice adoption. It was not uncommon for families to rear children left parentless, and childless adults would sopmetimes take the child of another family and bring it up. The children, however, retained the tribal affiliation of their biological fathers, and inherited land only from the property of the paternal lineage, not from the property of the lineage of the guardian.^[5]