中国区际收养立法的历时性审视

By reviewing sources of legislation and comparing different laws of adoption in Chinese Mainland, Hong Kong and Macao special administrative regions and Taiwan, the author points out that the inter regional laws of adoption vary in emphases and bear respective advantages. Efforts should be made in order to bring these laws of adoption into integration. For the improvement of the Law of Adoption of the Chinese Mainland, the author further suggests that the following points shall be taken into account: 1) the inclusion of adoption in the part of domestic relation when drafting the Civil Code; 2) paying close attention to conflict of inter regional laws of adoption so to regulate and adapt to the inter regional system; 3) encouraging the establishment of adoption relation through relaxing adoption requirements; 4) establishing a system of incomplete adoption so to protect benefits of parties concerned; and 5) setting up a period of 3-6 months of adoption on probation with a view to promoting more stable adoption relations.