Description du livre
This book, which updates and expands the third edition published by Springer in 2015, explains, compares and evaluates the social and legal functions of adoption within a range of selected jurisdictions and on an international basis. From the standpoint of the development of adoption in England & Wales, and the changes currently taking place there, it considers the process as it has evolved in other countries. It also identifies themes of commonality and difference in the experience of adoption in a common law context, comparing and contrasting this with the experience under civil law and in Islamic countries and with that of indigenous people. This book includes new chapters examining adoption in Russia, Korea and Romania. Further, it uses the international conventions and the associated ECtHR case law to benchmark developments in national law, policy and practice and to facilitate a cross-cultural comparative analysis.