RECOGNITION AND EFFECTS OF FOREIGN ADOPTION ORDERS
AbstractNo unanimity exists on the question of whether an English court, in ascertaining whether or not a foreign adoption attracts extraterritorial recognition, must look to the law of the domicile of adopted and adopter at the time of adoption, or whether it is sufficient that it look to only one of them and, if so, which one. Clearly, then, private international lawyers who try to construct a doctrine for the recognition of foreign adoption orders build upon ambivalent foundations. D.P. O’Connell discusses the unsatisfactory and contradictory nature of foreign adoption orders jurisprudence, and points out that the only conclusions to be drawn are inconclusive ones.
Keywords:Adoption, Conflict of Laws
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