Cultural variations in adoption
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There are several notable cultural variations in adoption. Adoption is an arrangement by which an
orphan An orphan (from the el, ορφανός, orphanós) is a child whose parents have died. In common usage, only a child who has lost both parents due to death is called an orphan. When referring to animals, only the mother's condition is usuall ...
ed 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 systems 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 * ...
, 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 were the hereditary military nobility and officer caste of medieval and early-modern Japan from the late 12th century until their abolition in 1876. They were the well-paid retainers of the '' daimyo'' (the great feudal landholders). They h ...
'' 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, ...
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 Guardian usually refers to: * Legal guardian, a person with the authority and duty to care for the interests of another * ''The Guardian'', a British daily newspaper (The) Guardian(s) may also refer to: Places * Guardian, West Virginia, Uni ...
", making it close to other nations' systems for
foster care Foster care is a system in which a minor has been placed into a ward, group home ( residential child care community, treatment center, etc.), or private home of a state-certified caregiver, referred to as a "foster parent" or with a family ...
. 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 Iraq,; ku, عێراق, translit=Êraq officially the Republic of Iraq, '; ku, کۆماری عێراق, translit=Komarî Êraq is a country in Western Asia. It is bordered by Turkey to the north, Iran to the east, the Persian Gulf and K ...
and
Malaysia Malaysia ( ; ) is a country in Southeast Asia. The federation, federal constitutional monarchy consists of States and federal territories of Malaysia, thirteen states and three federal territories, separated by the South China Sea into two r ...
have prohibitions against a child of Muslim parents being adopted by non-Muslim individuals.


Korea

In traditional
Korea Korea ( ko, 한국, or , ) is a peninsular region in East Asia. Since 1945, it has been divided at or near the 38th parallel, with North Korea (Democratic People's Republic of Korea) comprising its northern half and South Korea (Republic o ...
n 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 An orphanage is a residential institution, total institution or group home, devoted to the care of orphans and children who, for various reasons, cannot be cared for by their biological families. The parents may be deceased, absent, or a ...
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 Marriage, also called matrimony or wedlock, is a culturally and often legally recognized union between people called spouses. It establishes rights and obligations between them, as well as between them and their children, and between ...
, is meant to create enduring connections and social solidarity among families and lineages. Among the
Mbuti The Mbuti people, or Bambuti, are one of several indigenous pygmy groups in the Congo region of Africa. Their languages are Central Sudanic languages and Bantu languages. Subgroups Bambuti are pygmy hunter-gatherers, and are one of the old ...
people, sister exchange is the common form of marriage.


India

There is no uniform adoption law in
India India, officially the Republic of India (Hindi: ), is a country in South Asia. It is the seventh-largest country by area, the second-most populous country, and the most populous democracy in the world. Bounded by the Indian Ocean on the so ...
; 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 Guardian usually refers to: * Legal guardian, a person with the authority and duty to care for the interests of another * ''The Guardian'', a British daily newspaper (The) Guardian(s) may also refer to: Places * Guardian, West Virginia, Uni ...
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 adoptions. 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 Solomon Islands is an island country consisting of six major islands and over 900 smaller islands in Oceania, to the east of Papua New Guinea and north-west of Vanuatu. It has a land area of , and a population of approx. 700,000. Its capit ...
, 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 C ...
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 C ...
, "to feed"). Ties to the biological family are not normally severed.
Kiribati Kiribati (), officially the Republic of Kiribati ( gil, ibaberikiKiribati),Kiribati
''The Wor ...
culture also practice this fluid adoption, called "tibu".
Tahiti Tahiti (; Tahitian ; ; previously also known as Otaheite) is the largest island of the Windward group of the Society Islands in French Polynesia. It is located in the central part of the Pacific Ocean and the nearest major landmass is Austra ...
ans 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 F ...
(
Solomon Islands Solomon Islands is an island country consisting of six major islands and over 900 smaller islands in Oceania, to the east of Papua New Guinea and north-west of Vanuatu. It has a land area of , and a population of approx. 700,000. Its capit ...
) 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


References

{{Adopt Adoption forms and related practices Adoption, fostering, orphan care and displacement