가족주의 가치를 공유한 국가들의 입양법 국제비교에 관한 연구

Abstract

This study analyzed the adoption laws of countries with familistic values. Four countries (Italy, Spain, India, and Ireland) that South Korea shares common values with were selected for comparison. The adoption laws of these countries related to domestic adoption were analyzed in terms of adoptable children, the eligibility of the adoptive parent(s), the consent for adoption by the birth parent(s), and the adoption process (adoption arrangements and adoption orders). After analyzing the adoption laws of each country, the specific items which reflect familistic values in adoption laws were discussed related to the implications for Korean adoption practices. Based on the results of the study, suggestions for a new adoption law system which adheres to the principle of the “best interests of the child” and also reflects the reality of adoption practices in Korea were given. Also, by sharing the experiences of these counties, adoption practices in Korea could be improved upon.