“Adoption was such a positive alternative to abortion, a way to save one life and brighten two more those of the adoptive parents”. George W. Bush.In India there are several religions but there is no specific adoption law which governs the adoption of all religions. Adoption of a child in India was the province of personal laws where Hindus can adopt, under the Hindu Adoptions and Maintenance Act 1956 (HAMA). Whereas Muslims, Christians, Jews and Parsis do not have their own Personal law which governs adoption, which does not allow them to adopt a child and give him/her might not his family name, and it can only become the guardian of the child, under the Guardians and Wards Act, 1890. Hindus, Sikh, Buddhists, and Jains are governed by the Hindu Adoption and Maintenance Act 1956. The Government of India has taken certain steps to enact a uniform law for adoption and enacted Juvenile Justice (Care and Protection of Children) Act 2000. This Act was religiously neutral and applied to both Hindus and non-Hindus; for Hindus this law was redundant because HAMA applied to them and looked after adoption. It has now been replaced by Juvenile Justice (Care and Protection of Children) Act 2015, read with subsidiary rules and regulations such as the Adoption Regulations 2017 (the JJ Act). This paper centers on child adoption under various religions and also looks at the important differences regarding adoption under HAMA and the JJ Act 2015. This paper also assesses if these two statutes parallel enough to satisfy the needs of children for adoption and parents to adopt, or if there is a need for Special Uniform Law specifically for Adoption of Children.

Child Adoption Laws in India ; Effect of international laws

For a long time, there have been customary circles in order to assist a childless couple to have a child, particularly a son, in order to continue family lineage, succession, fulfill some duties or spiritual purposes, etc. However adoption is subsequently child focused, as stated in the report on the inter-country adoption reportedly application of ‘paramount and welfare of the child’ is the core subject matter in adoption. Adoption in India has not been practiced in a large way because of the socio-economic backwardness of the society and legal technicalities; thus it has always been considered as a private family matter. Thus, children who have been adopted in other countries are found to be exploited by being employed as domestic workers and have been victims of child trafficking.

Inter-country adoption has been the most controversial, complicated and sensitive matter that involves the values and processes around citizenship, migration, socio-economic status of the adopting parents and societies and cultures of the adopting parents. For these reasons, it has become necessary to legislate, as well as open up the possibilities for regulations and not just

legislative process, in favour of structured collaborations between permitting and authorising state and responsible social authorities. The same principles have been adopted and consideration of governmentality has been also given in Public and Private International laws. The Guardians and Wards Act, 1890 and the Hindu Adoption and Maintenance Act, 1956, and international instruments associated therewith were used to identify a statutory basis for laws for regulating such adoptions, as reported by CARA. The Hague Convention on Protection of Children and Co-operation in respect of inter-country adoption serves as the grundnorm which helps frame provisions for preventing illegal, irregular, premature or ill-prepared adoptions abroad for children and families.This Convention, using a regime of national central authorities, supports the United Nations Convention on the Rights of the Child (Article 21) in ensuring that inter-country adoptions are made in the best interests of the child and have due regard to his/her Fundamental Rights and to protect against the abduction and sale of children. The Hague Convention supports both private and independent adoptions, inter-country adoptions by accredited authorities and the prospective eligibility and suitability of adoptive parents. Adoption in India are governed by mainly two Laws -

• Hindu adoption and maintenance Act , 1956 (For Hindu , Jain , Sikh ,Buddhist )
• Juvenile Justice( Care and Protection of Children )Act , 2015 CARA comes into the picture when parents take the route of JJ Act for adoption.

CARA: Scope and Operational Aspects

The Central Adoption Resource Agency (CARA) is an agency of Ministry of Women and Child Development, which was created in June 1990 to monitor, regulate, and promote adoption of orphaned, abandoned, and surrendered children, with a primary goal to provide children in care (children in need of care and protection) with families. Further in 2015, the practice of adoption underwent a major change, and after the creation of Child Adoption Resource Information and Guidance System, i.e. CARINGS, the practices of adoption became friendlier and more transparent. The Ministry of Women and Child Development established it as a system of centralized units and, with the help of all agencies, a database of children who were adoptable and a list of prospective parents was created to ensure seamless transition in the process of adoption.However, the data collected for the year 2022 indicates that 26,734 prospective adoptive parents registered with CARA (Central Adoption Resource Authority), are awaiting referral for in-country adoptions. 1,205 prospective adoptive parents are awaiting for intercountry adoptions 118th Report of the Parliamentary Standing Committee on Review of Guardianship and Adoption Laws 2022, p. 31, which states that according to information provided by Ministry of Women and Child Development, the average time taken for prospective adoptive parents to get referrals for children in the age of 0-4 years is about two years.

Comparative Analysis between HAMA and JJ Act ( Concerning Adopting Children in India)

At present, India has two distinct and parallel legislative frameworks for adoption under the HAMA and the JJ Act.There are a couple of fundamental differences between these laws. The JJ Act is secular law and HAMA law is based on religion ,which legalises and facilitates adoptions for all religions and peoples (including Hindus) whereas the HAMA is confined solely to Hindus; the adoption process under the JJ Act is overseen by governmental agencies whereas the HAMA allows Hindu parents to directly adopt a Hindu child without government agency involvement (where applicable the adoptions still must follow certain conditions enumerated in HAMA). This article will outline who is able to adopt a child under the two regimes.

1.Regarding Capacity to adopt a child in India

1. Married Couples who have no child

Under HAMA, when adopting a child of the opposite gender, there has to be a difference of 21 years minimum lineal. There are no other conditions stated under HAMA for adoption by married couples. Under the JJ Act, married couples may adopt after they establish a stable marital relationship for two years (Radhika Gaggar, 2021). On an additional note, you should be mindful of the following age related terms: the age of the child eligible for adoption depends on the total age of the married couple. For example, if the married couple's total age is 90 - a couple may only adopt a child younger than 4 years old. There must be an age difference of at least 25

years between the couple and the child they adopt. This age specific language does not apply to relative placements or step-parent adoption.

1. Married couples with one child

Under the HAMA, a married couple can adopt a son where they have no son, son’s son, or son’s son’s son, and can adopt a daughter, if they have no daughter or son’s daughter, living at the time of the adoption. References to "son" and "daughter" will include both biological as well as previously adopted sons or daughters respectively. There is no such limitation under the JJ Act and married couples with three or more children would not be eligible for adoption other than in the case of children with special needs or hard-to-place children (i.e. children who have been without placements and referrals for a long time) or it is a relative or step-parent adoption.

2. A MARRIED PERSON WITHOUT CONSENT OF THEIR SPOUSES

The HAMA and JJ Act require the married person's spouse both male or female, to give the consent to adopt. There is the practical difficulty if the married couples are separated but the spouse has to still consent to the adoption.

3. Unmarried (single or divorced) individual

The HAMA allows unmarried persons either male or female to adopt if they are adults and of sound mind. The same rule for married couples applies to married persons in adoption, in that there must be at least an age difference of 21 years or more between the adoptive parent and the adopted child where a Hindu adopts a child of the opposite sex. A single individual can adopt under the JJ Act Even though an unmarried female can adopt a child of either gender, an unmarried male cannot adopt a girl. Whether the PAP is allowed to adopt will depend on what age the child is adopted. As previously noted, in the case of married couples,there must be an age difference of at least 25 years between the child and the PAP. An unmarried parent over the age of 55 years cannot adopt. Age restrictions do not apply to adoptions by relatives or a step-parent.

Furthermore, if an unmarried individual already has a child, the same restrictions for adoption of a child by married couples apply.

4. Transgender couples

Equally, the HAMA does not specifically permit adoption of children by homosexual couples. The JJ Act nowhere stipulates that a same sex couple may not adopt a child as long as the couple has been in a stable matrimonial relationship for the previous 2 years.However since same-sex marriages are not yet recognized in India, same-sex couples are not allowed to adopt a child as a couple. Nevertheless, either one of the partners could potentially adopt a child as an individual and raise the child as a couple.Live-in couples were previously denied adoption rights because they were depicted as ‘Walk-in and Walk-out’ relationships which labelled them as unstable and unsuitable for children because of the disturbed environment created. CARA had cited the same reason in a circular dated 2018 considering Live-In couples to be unqualified to adopt a child. However, the authority then revoked its previous statement and subsequently granted adoption rights to live-in couples, but on a case-to-case individual basis.The application made by the live-in couple with respect to adoption would be assessed using several factors; for example, the time period of relationship, shared household, intention of parties, public socialization, etc. These factors, in other words, represented the relationship in the nature of marriage, by reference to the case of D. Velusamy v. D. Patchaiammal.In this case, facts that were irrelevant to the ratio decidendi that is considered in the paper, the court considered the requirements for common law marriage as the considerations that justified a relation to be a marriage-like relationship. The above statements depicted this transition of live-in couples as, being socially unacceptable, to then being socially and legally equivalent to married couples, and then are being considered for being adoptive parents, and demonstrated the change that has occurred with live-in couple's adoption laws. This present shift has some pertinence to the aim of the paper, that the adoption rights of the queer community can also follow a similar course whereby such considerations are taken into account and also, other factors can also be introduced that would not act counter-intuitive to the aim of the laws. However, this would not occur without the legalization of same-sex marriage which is still a legal issue yet to be remedied.

5. Regarding Step-Parents:

The JJ Act very clearly allows a step-parent to adopt a child of his/her partner from a previous marriage if the biological parent(s) have surrendered the child. The HAMA has no similar provisions in the adoption process for step-parents, but there is also no prohibition against it.

6. Regarding Relatives:

The JJ Act has a much easier procedure for adoption by a relative than for a non-relative. A number of the preconditions regarding ages and number of children do not apply to PAPs who are relatives. The relatives recognized as per the JJ Act are the paternal or maternal uncle/aunt and paternal or maternal grandparents. The HAMA does not have similar provisions for adoption by relatives, but it does not prohibit adoption by relatives either.

7. Regarding Adoption of two Child of same gender - Harmonious construction between HAMA and JJ Act

In (Re: Adoption of Payal Sharinee Vinay Pathak and Sonika Pathak, 2010), the question before the Bombay High Court was whether a couple already having a biological child could adopt another child of the same sex as their existing child. The court held that in harmonising HAMA and the JJ Act that the JJ Act trumps general legislation because it prescribes special practices for adoption of a small group of people, such as those that are abandoned, relinquished or orphaned children (i.e., HAMA). In light of the JJ Act did not prohibit parents adopting a child of the same sex parallel to their existing child, the court concluded that a couple can adopt a child of the same sex as their existing child. The Act is an exclusive and specific authority which is resorted to when it comes to orphaned or surrendered children and there are no limits on individual adoption and the JJ Act applies to all such cases where children are (surrendered). In addition, as per sec 56(4), all the inter country adoptions are under the example of regulation of this statute (Yash Arjariya, 2022).

DIFFERENCE BETWEEN HINDU ADOPTION AND MAINTENANCE ACT, 1956 AND GUARDIANS AND WARDS ACT, 1890

India's adoption laws are governed by The Hindu Adoption and Maintenance Act, 1956, which allows Hindus to legally adopt a child. Other religions can adopt a child in 'guardianship’ authority under the Guardians and Wards Act, 1890. The Guardians and Wards Act, 1890, applies to Christians, Muslims, Parsis, and Jews, but does not confer the child's status. The Hindu Adoption and Maintenance Act, applicable to Hindus, Jain, Buddhists, and Sikhs, grants full status and inheritance rights. Adoptive parents must leave wishes through a will.

Applicability:

• Hindu Minority and Guardianship Act, 1956: This act applies to Hindus, along with Buddhists, Jains and Sikhs. It deals with issues relating to the guardianship of minors, and is intended to apply to the specified religions only.

• Guardians and Wards Act, 1890: This act does not specify or limit itself to a religion, and applies to all persons, of any religion or community in India. It is a secular law governing the appointment and powers and responsibilities of guardians for minors.

Scope:

• Hindu Minority and Guardianship Act, 1956: This act is primarily oriented to the guardianship of minor children in the Hindu religion and the rules surrounding the appointment of guardians for minors and their powers and responsibilities related to them.
• Guardians and Wards Act, 1890: This act is more comprehensive in nature and deals with the issues of guardianship in respect of minors irrespective of their religion. It covers the appointment of guardians and guardianship in respect of minors, but it also includes issues pertaining to the welfare and protecting the interest of the minor.

Guardianship:

• Hindu Minority and Guardianship Act, 1956: The Act details that the father is the natural guardian of a Hindu minor, the mother comes next. The Act also contains provisions for appointing other guardians.
• Guardians and Wards Act, 1890: The statute enables the court to appoint a guardian, called “guardian of the person” or “guardian of the property”, according to the best

interest of the minor. There is liberal discretion for the court to appoint guardians as provided in this statute.

Welfare of the Child:

• Hindu Minority and Guardianship Act, 1956: While this Act talks about the welfare of the children, it primarily deals with the order of preference of the natural guardians of children who belong to the Hindu community.
• Guardians and Wards Act, 1890: The statute is more holistic, with emphasis on the welfare and the best interest of the minor child without regard to religion or the community the child may belong. The Court may take any decisions it believes in the best interests of the child.

Disputes recognition of guardianship:

Hindu Minority and Guardianship Act, 1956: While this Act contains more specifications, relating to the hierarchy of natural guardianship, of a Hindu. The disputes regarding guardianship may be resolved on the basis of the hierarchical priority and religion of the minor child. In short, the Hindu Minority & Guardianship Act, 1956 is a specialized law which deals specifically with the guardianship of Hindu minors, while the Guardians and Wards Act, 1890 is a general law which applies to minors of all faiths, and puts emphasis on the best interests of the child.

Adoption under different religions :

Adoption is the legal project of a child theme which does not have a home of its own. It is covered by various personal laws in India. Very few of those need to go to court under the Guardian and Wards Act, 1890, like how Muslims, Christians, Parsis, very few of them go. They can only take one child for foster care. Once a lad is a major, that is, 18 years of age a child may cut all the cords. Also, there is no legal right to inheritance for such a child. There are 3 different legal systems which we have that are prevalent in regard to adoptive parents in India which are the Guardians and wards Act, 1890, Hindu Law and Muslim law. And the guardians are of three sorts, natural, testamentary, and that appointed by law.

Child Adoption Under Hindu Law

Under Hindu Law, adoption is a sacrament and not a secular act. The end of the adoption may be divided in:1. To ensure continuity of one’s descent 2. To the quality of his/her funeral rights. Hindu: as per the Shastras in Hindu, the adopted child should be a representative of a natural son, therefore entitled to the love and affection at par with a natural son. Once a child is adopted, he steps into another pair of adoptive parents, and all the maternal and paternal relations spring into existence on that side. Under the provisions of section 3, the adopted child would not be legally entitled to marry another child of his/her parents ( whether natural or adopted). Though, the recent adoption laws are framed and written with the intention to instill a compassionate and a cure to a childless person/couple one way and to render a proper family life and want a rejected, unwanted, controverted, disputed, lost in other words orphan child on the other side. Provision Under Hindu Adoption And Maintenance Act, 1956 Hindu Adoption and Maintenance Act, 1956 is applicable to Hindus only, and the following are Hindus according to Section 1 of the Act. The description also refers to persons who are Hindus by religion, including persons professing Virashaiva, Lingayat, or a follower of the Arya Samaj or the followers of Buddhistic, Jaina or Sikh religion. Moreover, this Act applies to every person who is not a Muslim, Christian, Parsi or Jew by religion as they have their special rules.This Act may also apply to any child, legitimate or illegitimate, if his or her parent being depicted as unknown and is being raised as a Hindu, Buddhist, Jain or Sikh. This Act has regulated many adoption cases in India since it was brought into force. The Act was enforced on 21st Dec 1956. Prior to this Act, there was eligibility only for males to be adopted but this Act provided eligibility for females too.The Hindu Adoption and Maintenance Act, 1956, applies to the whole country except for the state of Jammu and Kashmir. The act is not only applicable to Hindus but also to Buddhists, Jains, Sikhs and to a person who is not by religion a Muslim, Christian, or Parsi.

(B) Status under Islamic Law

Under Islamic law, adoption is not permitted. Since there is no statute on adoption for Muslims, they must pursue the court pursuant to the Guardianship and Wards Act of 1890. When a Muslim adopts a child under the Act, the child is presumed to assert themselves to foster homes. Before the Shariat Act of 1937, Muslim adoption was accepted by custom. The father holds the predominant role under Muslim law and also distinguishes between custody and guardianship of a child. Both Sunni and Shia schools of thought are of the opinion that once alive, the father can only be regarded as the guardian of the child. Even after the father's death, the father remains the only guardian and mother is not one of the natural guardians.In some aspects the Islamic law of adoption is somewhat distinctive from that of other cultures and societies. The term Kafala is the Islamic term commonly understood as adoption. In Islam there are some restrictions when it comes to the principle of adoption.

• Adopted children retain their biological family names (surnames) and do not change their names to their adoptive family names. Adopted children belong to their biological parents, not their adoptive parents.
• If their biological family gives the child property/wealth, adoptive parents are responsible for ensuring that property/wealth is not confused with their own property/wealth. They will just perform as trustees.

Adoption under christian law and Parsi law

While adoption is not legally recognized under the applicable law of these jurisdictions, it is legally possible to adopt from an orphanage in these jurisdictions with the approval of the court under the laws on Guardians and the currently outdated Act of Baths. There is no adoption law for a Christian. Adoption is a legal connection of a child to a family and, therefore, a matter of personal law. Since there is no adoption law for Christians, they can only go to the law under the provisions of the Guardians and Wards Act of 1890. The Commissioner of Women from the country has pointed out that there is a need for uniform laws on adoption. According to this stated Act, the adoption of children by Christians is only permitted under the foster care system, and an adopted child can sever all connections upon achievement of adulthood. Thus, a child has no legal claim to a die investment. In these communities too the personal laws do not recognize adoption, and in this case, an adoption can only occur from an orphanage with permission of the court under the Guardians and Wards Act. A Christian has no law on adoption. Christians do not have the laws to adopt and approach courts under The Guardians and Wards 1890.Christians in India have the ability to adopt children through section 41 of the Juvenile Justice (Care and Protection of Children) Act 2006 and Guidelines and Rules provided by various State Governments. The personal laws of these communities do not recognize adoption and so an adoption can also take place from an orphanage with the Court's permission under Guardians and wards act. A Christian has no adoption law. In Re: Manuel Theodore D'souza 1999: A Christian couple wanted to adopt a child. But the petitioner being Christians are entitled to be appointed as guardians.

Need of reforms in Adoption laws

With the passage of time, the scope and relevance of a Common Civil Code for all citizens, irrespective of religion, and for the protection of their fundamental and constitutional rights has become necessary. No one should have any qualms in this regard. While stressing that the foundations of secularism would only be enhanced with a Common Civil Code, Mahatma Gandhi stated: “I do not expect India of my dreams to develop one religion, i.e. to be wholly Hindu or wholly Christian or wholly Mussalman, but I want it to be wholly tolerant, the religions working side-by-side with one another”. It cannot be said that the personal laws alone have taken the initiative in doing their best to provide for easy custody and adoption. It is to be noted that the legislature has very recently introduced the GWA to give remedy to those who are not covered by adoption provisions in their personal law.Chief Justice Chagla, an eminent Muslim Judge, stated: "An (Article 44) is a compulsory provision binding on the legislature. The Constitution was enacted for the entire country, it binds the entire country and every section and community has to accept the provisions of the Constitution and its directions."The implementation of a Uniform civil code will provide the ability to legally adopt a child to all other religions of an India as well as improve the social life of a parent without children.

Adoption has to be one of the concepts that has changed substantially during the evolution from our prehistoric society to modern society. Adoption establishes a bond that did not exist, however artificial, and it is permanent, respectively. Except for Hindus, others do not have guaranteed systems for the regulation of adoptions similar to those of Hindus. There is no prohibition against adoption in Parsi, Christian, or other religious laws. None of those cultures have personal or statutory laws regarding adoption. In their case, tradition governs adoption practices,the current adoption law is too complex and annoying for adoptive parents, the Supreme Court on 13 August 2025 observed that the adoption process needed to be made more easier and simplified to motivate childless couples to take the legal route of adoption rather than illegally adopting. A bench of Justice B V Nagarathna and K V Viswanathan, while hearing a case on child trafficking problems in the country ,said that the timescale for adoption had made people look at illegal adoption routes to obtain children in countries as the processes took years . It said not having children is a great social stigma and so people want children badly but the processes we have to adopt legally is cumbersome. The actual number of adoptions passed 4500 in 2025-26 as of March 31, the highest in 11 years.However ,for many prospective adoptive parents (PAPs) the road to adopt a child remained difficult with an average of waiting period of 3.5 years for PLA's seeking infants and young children. The Central Adoption Resource Authority (CARA) dashboard shows there are more than 36,616 PAPs of various categories registered for adoption with barely 2756 children available for adoption. The current adoption processes just take too long.

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