Full adoption in England and Wales and France: a comparative history of law and practice (1926–2015)

Abstract

Why do the British adopt far fewer children from abroad but more domestic children than the French? To examine this question, this article compares the history of adoption law and practice in France and England and Wales. Although these countries have had similar adoption laws since the 1920s, there have long been many more adoptions in England and Wales. This is partly due to the greater numbers of abused and neglected children being put forward for adoption in the UK. In addition, memories of the forced migration of children, coupled with heated debate over transracial adoption in the 1980s, cast doubt on the idea that intercountry adoption might benefit children. Consequently, local authorities give higher priority to the placement of children born in the UK with its system of open adoption. In contrast, French prospective adopters face a dearth of domestic children available for adoption and so turn their attentions overseas.