TN 15 (09-91)
GN 00307.230 Equitable Adoptions Outside the U.S
You must not make assumptions about the validity of equitable adoptions for periods (or areas) not listed in B. or whether these adoptions would be recognized by jurisdictions other than those shown.
B. List of countries
The following list provides information from the precedent opinions available on the recognition given equitable adoption (GN 00306.175) outside the U.S.
|Bolivia||Not recognized from 1961 to at least January 1979.|
|Canada British Columbia|| |
Not recognized prior to 1920.
From 1920 to at least January 1952, British Columbia would, in an appropriate case (not defined by precedent material), recognize the doctrine of equitable adoption.
| New Brunswick||Recognized from 1927 to at least July 1958, based on a contract to adopt. It must be clear that adoption is involved and not a guardian-type arrangement.|
| Newfoundland||Recognized from 1940 to at least May 1958. A contract to adopt is necessary but no opinion has been rendered as to whether the contract can be written or oral. It must be clear, however, that the child is adopted and that no other inference can reasonably be drawn.|
| Ontario||Recognized at least up to 1948. Not recognized from 1974 to at least November 1979.|
| Quebec||Not recognized to at least 1952.|
|Colombia||Not recognized from 1959 to at least June 1979.|
|El Salvador||Not recognized from 1955 to at least February 1986.|
|Fiji||Not recognized to at least December 1975.|
|France||Not recognized to at least January 1965.|
|Germany, West||Not recognized to at least December 1957.|
|Honduras||Not recognized to at least October 1963.|
|Italy||Not recognized to at least June 1959.|
|Jamaica||Not recognized from at least January 2, 1958 to at least August 1975.|
|Mexico||Not recognized from at least 1960 to at least April 1983.|
|Nigeria||Not recognized to at least March 1972.|
|Norway||Not recognized to at least January 1953.|
|Philippines||Not recognized from at least 1951 to at least July 1964.|
|Yugoslavia||The law in effect from April 1, 1947 to at least September 1959 does not require a written decree or court order of adoption. Instead, a petition of adoption and an agreement of the parties, signed by them and approved by the Commissioner of Social Welfare is necessary.|