There are several notable cultural variations in adoption.
Adoption
Adoption is a process whereby a person assumes the parenting of another, usually a child, from that person's biological or legal parent or parents. Legal adoptions permanently transfer all rights and responsibilities, along with filiation, from ...
is an arrangement by which an
orphaned child or one whose biological parents are unable to care for them is "adopted". While all societies make provision for the rearing of children whose own parents are unavailable to care for them, cultures and
legal system
The contemporary national legal systems are generally based on one of four basic systems: civil law, common law, statutory law, religious law or combinations of these. However, the legal system of each country is shaped by its unique history an ...
s treat an adopted child in different ways ranging from equivalent status to
legitimate biological children to
guardianship.
There are variations regarding inheritance of property and
rank
Rank is the relative position, value, worth, complexity, power, importance, authority, level, etc. of a person or object within a ranking, such as:
Level or position in a hierarchical organization
* Academic rank
* Diplomatic rank
* Hierarchy
* H ...
, for example, under a system of adoption, if a parent dies
intestate
Intestacy is the condition of the estate of a person who dies without having in force a valid will or other binding declaration. Alternatively this may also apply where a will or declaration has been made, but only applies to part of the estat ...
, the adopted child stands in exactly the same position regarding inheritance as a biological child. Inheritance of rank varies across jurisdictions and time periods, in pre-modern Japan, a child could inherit the parent's aristocratic title or ''
samurai'' rank, whereas in the United Kingdom (which only introduced legal adoption in 1926), only a biological child could inherit an
aristocratic title, even if raising or providing for parentless children was a common practice.
Arab
In
Arab
The Arabs (singular: Arab; singular ar, عَرَبِيٌّ, DIN 31635: , , plural ar, عَرَب, DIN 31635: , Arabic pronunciation: ), also known as the Arab people, are an ethnic group mainly inhabiting the Arab world in Western Asia, No ...
cultures, if a child is adopted, he or she traditionally does not become a "son" or "daughter", but rather a
ward
Ward may refer to:
Division or unit
* Hospital ward, a hospital division, floor, or room set aside for a particular class or group of patients, for example the psychiatric ward
* Prison ward, a division of a penal institution such as a pris ...
of the adopting caretaker(s). The child's surname is not changed to that of the adopting parent(s), who are publicly recognised as "
guardians", making it 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. In addition, Islamic countries such as
Iraq and
Malaysia have prohibitions against a child of Muslim parents being adopted by non-Muslim individuals.
Korea
In traditional
Korean culture, adoption almost always occurred when another family member (sibling or cousin) gives a male child to the first-born male
heir of the family. Adoptions outside the family were rare. This has also been the reason why most orphaned Korean children have been exported to countries such as the United States. This is also true to varying degrees in other Asian societies. To this day
orphanages are still common all over South Korea.
Africa
On the other hand, in many African cultures, children are often given to adoptive families. By giving their child to another family, the birth family seeks to create enduring ties with the adoptive family. The placing family may receive another child from that family, or from another. In the same way as giving their child for adoption, the exchange of female relatives from one family to another, for
marriage, is meant to create enduring connections and social solidarity among families and lineages. Among the
Mbuti people, sister exchange is the common form of marriage.
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 become only
guardians under the Guardians and Wards Act of 1890. Guardianship expires once the child attains the age of 18 years. 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.
Pacific
"Fluid adoption" is common in
Pacific culture, and rarely are ties to the biological family severed, as traditionally has occurred in Western
adoption
Adoption is a process whereby a person assumes the parenting of another, usually a child, from that person's biological or legal parent or parents. Legal adoptions permanently transfer all rights and responsibilities, along with filiation, from ...
s. Many Europeans and Americans associate adoption as a solution to something gone wrong, e.g. unwanted pregnancy (by genetic parent) or infertility (by adoptive parent). By contrast, most of the Pacific cultures, for example in
Sikaiana
Sikaiana (formerly called the Stewart Islands) is a small atoll NE of Malaita in Solomon Islands in the south Pacific Ocean. It is almost in length and its lagoon, known as Te Moana, is totally enclosed by the coral reef. Its total land s ...
in the
Solomon Islands, prefer that children move between different households. Fosterage is viewed as a way to create and maintain close personal relations, and parents traditionally do not refuse to let others take their children. These transfers of children between different caretakers and households are not exclusive, and they do not permanently separate the children from their biological parents.
New Zealand
Māori
Māori or Maori can refer to:
Relating to the Māori people
* Māori people of New Zealand, or members of that group
* Māori language, the language of the Māori people of New Zealand
* Māori culture
* Cook Islanders, the Māori people of the Co ...
have a form of traditional adoption practised within extended family called ''
whāngai'' (
Māori
Māori or Maori can refer to:
Relating to the Māori people
* Māori people of New Zealand, or members of that group
* Māori language, the language of the Māori people of New Zealand
* Māori culture
* Cook Islanders, the Māori people of the Co ...
, "to feed"). Ties to the biological family are not normally severed.
Kiribati culture also practice this fluid adoption, called "tibu".
Tahitians practice ' (literally "giving to eat") adoption. Its basic functions are comparable to the ones of other traditional adoption practices, notably in Africa; a child can be "given" with the agreement or on the initiative of the family council for a variety of reasons, and they can even be asked for and given before birth.
Tikopia
Traditional
Tikopia
Tikopia is a high island in the southwestern Pacific Ocean. It forms a part of the Melanesian nation state of Solomon Islands but is culturally Polynesian. The first Europeans arrived on 22 April 1606 as part of the Spanish expedition of Pedro Fe ...
(
Solomon Islands) society did not practice adoption as it is traditionally understood in Western societies. It was not uncommon for families to rear children left parentless, and childless adults would sometimes 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.
[Firth, Raymond, "We the Tikopia, Beacon Press Edition, 1936, 1957, 1963, .pp 190-193]
See also
*
Adoption
Adoption is a process whereby a person assumes the parenting of another, usually a child, from that person's biological or legal parent or parents. Legal adoptions permanently transfer all rights and responsibilities, along with filiation, from ...
References
{{Adopt
Adoption forms and related practices
Adoption, fostering, orphan care and displacement