RAJIV GANDHI NATIONAL UNIVERSITY OF LAW, PUNJAB

5th Semester

CONFLICT OF LAWS

TOPIC: RECOGNITION OF FOREIGN ADOPTION AND

ADOPTION BY FOREIGN PARENTS UNDER PRIVATE
INTERNATIONAL LAW

Submitted To: Dr. Sukhwinder Kaur Virk Submitted By: Akanksha

Goel

(Asst. Professor of Law) Roll No.: 18142

Group No. 24
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 TABLE OF CONTENTS

Chapter 1: Introduction..............................................................................................................3

1.1 Meaning of Adoption.......................................................................................................3

1.2 Types of Adoption............................................................................................................3

Chapter 2: International Conventions to Regulate Inter Country Adoption..............................5

2.1 UN Convention on the Rights of Child (CRC)................................................................5

2.2 Hague Convention............................................................................................................6

Chapter 3: Indian Perspective....................................................................................................8

3.1 Legislations......................................................................................................................8

3.2 Role of CARA..................................................................................................................9

3.3 Important Case Laws........................................................................................................9

Chapter 4: Perspective of Other countries...............................................................................11

4.1: USA...............................................................................................................................11

4.2: UK.................................................................................................................................12

Chapter 5: Challenges Faced and Suggestions.........................................................................13

5.1 Challenges Faced...........................................................................................................13

5.2 Suggestions................................................................................................................14

Chapter 6: Conclusion..............................................................................................................16

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 CHAPTER 1: INTRODUCTION

1.1 MEANING OF ADOPTION

The word “Adoption” has been derived from the Latin word “Adoptare” which means to
choose. It is the act of legally placing a child with someone other than those to whom they
were born. In Legal terms, adoption can be defined as a legal method of creating between the
child and one who is not the natural parent of the child an artificial family relationship
analogous to that of parent and child. The Adoption laws varies from country to country,
therefore the need for Inter country adoption laws arises.

Adoption refers to the act by which an adult formally becomes the guardian of a child and
incurs the rights and responsibilities of a parent. At the conclusion of the formal process, a
legal relationship between child and guardian will have formed. The legal relationship results
in the adoptee becoming the legal heir of the adopter and terminates any legal rights then in
existence with the natural parents1.

Adoption is the process by which an adult becomes the official guardian to a child thereby
incurring all the parental responsibilities. Once the process is completed, a legal relationship
between the child and the adult is initiated. Here, the child becomes the legal heir to the
adoptive parent and any existing rights with the biological parents are terminated2.

1.2 TYPES OF ADOPTION

Adoption can be categorized into the following categories:

 Open Adoption: With the open adoption, the birth mother is given the right to choose
the adoptive parents. Here, the birth mother might also maintain some contact or
visitation rights. This kind of adoption involves making a plan that may suit
everyone’s expectations and needs. The access is usually granted when the adopted
child reaches the age of 18 (in most countries).
 Semi-open adoption: It does not require the birth parents and adoptive parents to be
in touch with each other. However, the mother may keep receiving letters or

1
‘Adoption’, Legal Information Institute, Cornell Law School, https://www.law.cornell.edu/wex/adoption (last
accessed 16 November 2020).
2
Gabriel Taylor, ‘The Legal Definition of Adoption’ (2017), Oxford Legal, http://www.oxfordlegal.com/legal-
definition-adoption/ (last accessed 16 November 2020).

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 photographs from the adoptive parents or through the adoption agency she is
registered with. This may continue until the child reaches the legal age. At any given
point of time, semi-adoption may get converted into an open or closed adoption.
 Closed Adoption: During a closed adoption, the birth mother gives up all the parental
rights and the state is given the authority to choose the adoptive parents for the child.
Sometimes, the medical information of the birthing parents may be shared with the
adoptive parents. However, sometimes there may be strict enforcement of the
regulation and no information, whatsoever, is shared with the adoptive parents. This
may happen in cases when a child is rescued or removed from an abusive
environment.
 Intra Family Adoption: If the biological parents of a child die, get married to
someone else, or are not in a capacity to take care of their child, a member of the
family or the step-parents may legally adopt that child.
 Domestic Adoption: When the adoptive parents and birth parents belong to the same
country, and the adoption happens within the country, it is called domestic adoption.
The couple who wish to adopt a child may register with any registered government
agency. An investigating officer will verify their particulars and also assess if the
couple is eligible to adopt a child or not. Once the formalities are complete, the couple
may adopt a child.
 International Adoption: When the citizens of one nation wish to adopt a child from
another nation, it is called international adoption. International adoption laws are
different in all countries, and some countries do not even allow international adoption.
In India, domestic adoption holds priority. The next in line are Non-resident Indians
(NRIs) or persons of Indian origin (PIOs) and then international citizens are given
preference for international adoption in India.

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 CHAPTER 2: INTERNATIONAL CONVENTIONS TO REGULATE INTER
COUNTRY ADOPTION

Inter-country adoption (ICA) can be defined as adoption of a child by a person of another

country. Conventions such as the Hague Convention3 (HC) and UN Conventions on Rights of
Child4 (CRC) are two major international frameworks to regulate adoption in Private
International Law.

2.1 UN CONVENTION ON THE RIGHTS OF CHILD (CRC)

The CRC places major emphasis on the importance and role of the parents and family as the
child’s primary caregivers, and requires, first and foremost, States to assist them when they
have difficulty in fulfilling their responsibilities appropriately. Only when, despite such
efforts, the child is “deprived of his or her family environment”, or cannot be allowed to
remain therein in light of his or her best interests, does the obligation of the State to “ensure
alternative care for the child” becomes operative 5. And it is only when, in that case, the State
is unable to ensure that the child is “placed in a foster or an adoptive family” or is cared for
“in any suitable manner in the child’s country of origin” that inter-country adoption “may be
considered”.

The Convention has 54 articles that cover all aspects of a child’s life and set out the civil,
political, economic, social and cultural rights that all children everywhere are entitled to. It
also explains how adults and governments must work together to make sure all children can
enjoy all their rights. Every child has rights, whatever their ethnicity, gender, religion,
language, abilities or any other status6.

The Convention must be seen as a whole: all the rights are linked and no right is more
important that another. CRC’s Article 21 includes the obligation to “ensure that the child
concerned in inter-country adoption enjoys safeguards and standards equivalent to those
existing in the case of national adoption.

3
Hague Convention on the Protection of Children and Co-operation in Respect of Intercountry Adoption, 29
May 1993, 33
4
Convention on the Rights of the Child, E/CN.4/RES/1990/74.
5
Supra, Note 4, art. 20.
6
‘What is the UN Convention on Child Rights’, UNICEF, https://www.unicef.org.uk/what-we-do/un-
convention-child-rights/ (last accessed 16 November 2020).

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The Committee on the Rights of the Child, which is the treaty body monitoring compliance
with the CRC, has expressed concerns over violations of inter-country adoption standards in
the case of many countries, and strongly recommends all States involved in inter-country
adoption that they ratify the Hague Convention as one means of addressing the problems.

2.2 HAGUE CONVENTION

The 1993 Hague Convention on the Protection of Children and Cooperation in Respect of
Inter-country Adoption specifically regulates the inter-country adoption and came into force
in 1995. The same has been ratified by 101 countries till date.

The Hague Convention sets out to do two main things, both unequivocally directed towards
protecting the child from illicit practices related to inter-country adoption, rather than to
promoting the practice as such:

1. “to establish safeguards to ensure that inter-country adoption takes place in the best
interests of the child and with respect for his or her fundamental rights as recognized
in international law”; and
2. “to establish a system of cooperation among Contracting States to ensure that those
safeguards are respected and thereby prevent the abduction, the sale of, or traffic in
children.”7

For Hague adoptions, the authorities in both countries must agree to go ahead with the
adoption. For non-Hague adoptions, requirements may vary from one country to another. The
Hague Convention does not allow private adoptions in the child's home country.

Adoption is a handled by the provinces and territories, and they all have and follow laws
implementing the Hague Convention. They can explain the rules you need to follow under
the Hague Convention and for adoptions from a country that is not a party to the Convention8.

The system of cooperation established by the HC revolves around a governmental “Central

Authority” in each country to oversee adoptions and to serve as focal point on inter-country
adoption issues with its counterparts in other States. The treaty foresees that “adoption
bodies”, or agencies, duly accredited by the Central Authority in the receiving country can

7
Supra, Note 3, art. 1.
8
‘What is Hague Convention?’ Government of Canada, https://www.cic.gc.ca/english/helpcentre/answer.asp?
qnum=1183&top=2 (last accessed 16 November 2020).

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carry out a range of tasks related to the adoption process, notably regarding assistance to
adoptive parents before, during and after the adoption takes place. If also specifically
authorized by the Central Authority in the country of origin, the adoption body can also
provide such assistance directly in that country.

The HC notably puts in place concrete application of the “subsidiarity principle”, setting out
procedures based on the fact that a child may be considered for inter-country adoption only if
“possibilities for placement of the child within the State of origin have been given due
consideration.”9 Other particularly important elements of the HC include: the requirement to
determine the fitness of applicants to proceed with an adoption; the implicit prohibition of
non-regulated and private adoptions, since all prospective adopters are to undertake the
process through the Central Authority or an accredited agency; prohibition of contact
between prospective adoptive parents and the child’s parents or other caregiver/s before the
child has been pronounced adoptable and valid consents have been obtained; commitment to
ensuring free and informed consent for adoption with no inducement of any kind; and the
automatic recognition of Hague-compliant adoptions by all States Parties10.

9
Supra, note 3, Preamble.
10
‘Hague Process’, U.S. Citizenship and Immigration Services, https://www.uscis.gov/adoption/immigration-
through-adoption/hague-process (last accessed 16 November 2020).

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 CHAPTER 3: INDIAN PERSPECTIVE

3.1 LEGISLATIONS

At the International level, India has ratified the Convention on the Rights of Child and the
Hague Convention on Inter-Country Adoption of Children. The principal law relating to
adoption in India under the Hindu system is contained in the Hindu Adoptions and
Maintenance Act, 195611 (HAMA).

Internal adoptions in India are governed by the Hindu Adoptions and Maintenance Act of
1956 and the guardianship and Wards Act of 189012. With respect to legislations governing
inter-country adoptions, there is no specific statute as of now in the country even though it is
a well-known practice and a long line of jurisprudence flow dealing with the issue. The
Juvenile Justice Act13 Also Provides for the adoption of abandoned and abused children by
people of all communities. Furthermore, the foreigners, who want to adopt Indian children
have to approach the court under the aforesaid Act. In case the court has given permission for
the child to be taken out of the country, adoption according to a foreign law, i.e., law
applicable to guardian takes place outside the country. 

The Juvenile Justice (Care and Protection of Children) Act, 2000 and The Amendment Act,
2006 guarantees rights to an adopted child as recognized under international obligations by
all Hague member countries. The JJ Act, 2000, however did not define ‘adoption’ and it is
only by the amendment of 2006 that the meaning thereof came to be expressed.

The amendment emphasized that adoption under this legislation would allow an adopted
child to become the “legitimate child of his adoptive parents, with the rights, privileges and
responsibilities attached to the relationship. This is a significant move considering till then,
adoption by non-Hindus was guided by the Guardian and Wards Act, 1890. Minority castes
such as Christians, Muslims or Parsis did not recognize adoption hence the adoptive parents
had to remain as guardians to their adopted children as per the Guardian and Wards Act,
1890.

In exercise of the rule making power vested by Section 68 of the JJ Act, 200014, the JJ Rules,
2007 were enacted, which now stand repealed by a fresh set of Guidelines published by

11
The Hindu Adoptions and Maintenance Act, 1956 (India).
12
The Guardianship and Wards Act, 1890 (India).
13
The Juvenile Justice (Care and Protection of Children) Act, 2000 (India).
14
Id. at 13, s. 68.

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Notification dated 24.6.2011 of the Ministry of Women and Child Development, Government
of India under Section 41(3)15 of the JJ Act. As a matter of fact, by virtue of the provisions of
Rule 33(2) it is the Guidelines of 2011 notified under Section 41(3) of the JJ Act which will
now govern all matters pertaining to inter-country adoptions virtually conferring on the said
Guidelines a statutory sanction16.

3.2 ROLE OF CARA

Central Adoption Resource Authority (CARA) is a statutory body of Ministry of Women &
Child Development, Government of India. It functions as the nodal body for adoption of
Indian children and is mandated to monitor and regulate in-country and inter-country
adoptions. CARA is designated as the Central Authority to deal with inter-country adoptions
in accordance with the provisions of the Hague Convention on Inter-country Adoption, 1993,
ratified by Government of India in 2003. CARA primarily deals with adoption of orphan,
abandoned and surrendered children through its associated adoption agencies17.

Adoptions are regulated by CARA which is an autonomous body under the Ministry of
Women and Child Development. CARA pointed out some of the loopholes in Indian
Adoption. CARA specifies the eligibility conditions, processing steps, documentation, costs,
court processes, foster care conditions, issuance of birth certificates and post adoption follow
ups.

The CARA guidelines depict in the beginning that it encourages in country adoption rather
than inter-country adoption and only where the child finds no suitable home in the country,
trans-national adoption would be considered.

3.3 IMPORTANT CASE LAWS

 Re Rasiklal Chhaganlal Mehta18: The question regarding the validity of inter-

country adoption was first debated in the well-known case of In Re Rasiklal

15
Id. at 13, s. 41.
16
Achina Kundu, ‘An Overview of Intercountry Adoption with Special Focus on India’ (2013), Manupatra,
http://docs.manupatra.in/newsline/articles/Upload/AAE0786F-285D-424E-B557-16F742371D48.pdf (last
accessed 17 November 2020).
17
‘CARA’, Central Adoption Resource Authority, Ministry of Women and Child Development, http://cara.nic.in/
(last accessed 17 November 2020).
18
Re Rasiklal Chhaganlal Mehta, AIR 1982 Guj. 193,

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 Chhaganlal Mehta whereby the Court held that inter-country adoptions under Sec 9(4)
of the Hindu Adoptions and Maintenance Act, 1956 should be legally valid under the
laws of both the countries. The adoptive parents must fulfill the requirement of law of
adoptions in their country and must have the requisite permission to adopt from the
appropriate authority thereby ensuring that the child would not suffer in immigration
and obtaining nationality in the adoptive parents’ country.
 Laxmikant Pandey v Union of India19: The Supreme Court of India in a public
interest litigation petition, Laxmi Kant Pandey v. Union of India, had framed the
guidelines governing inter-country adoptions for the benefit of the Government of
India. A regulatory body, i.e., Central Adoption Resource Agency (for short ‘CARA’)
was recommended and accordingly set up by the Government of India in the year
1989.
 Mr. Craig Allen Coates v. State through Indian Council for Child Welfare
and Welfare Home for Children20: In the case of Mr. Craig Allen Coates v.
State through Indian Council for Child Welfare and Welfare Home for Children[xi]
the Court held that where the adoptive parents fail to establish clearly the motive for
adopting a child from another country, then the adoption process would be barred and
be declared as mala fide and that CARA should ensure more stricter guidelines in this
regard.
 Varsha Sanjay Shinde & Anr. v. Society of Friends of the Sassoon Hospital and
others21: Bombay High Court in a recent judgment, Varsha Sanjay Shinde & Anr. v.
Society of Friends of the Sassoon Hospital and other, held that once a child is
approved by an Oversees couple after the due procedure is followed, the same child
cannot be shown to other Indian parents and that such Indian Parents then cannot
claim any right or priority to get the child merely because they are Indian Parents and
preference should be given to them over Overseas Indians and Foreign Couples.
Although the main issues was decided the Court kept the petition pending in order to
see the compliance of directions given by the Court for giving the child to the
Overseas Indian Couple and to ensure that the Indian Parents (Petitioners) also get a
child expeditiously.

19
Laxmi Kant Pandey v. Union of India, 1984 AIR 469.
20
Mr. Craig Allen Coates v. State through Indian Council for Child Welfare and Welfare Home for Children,
162(2009) DLT 605.
21
Varsha Sanjay Shinde & Anr. v. Society of Friends of the Sassoon Hospital and others, Writ Petition no. 9227
of 2013.

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 CHAPTER 4: PERSPECTIVE OF OTHER COUNTRIES

The Perspective of other countries such as the US and UK has been analyzed under this
section along with the laws and regulations of the country. The US governs ICA through a
newly formed act in 2000. On the other hand the UK governs the ICA on the basis of the
Children and Adoption act formulated in 2006.

4.1: USA

In USA the Intercountry Adoption Act of 200022, regulates the intercountry adoption.  The
major goal of the Act was to provide for implementation by the United States of the Hague
Convention. The law is recent so, is in consonance with the recent changes and trends and is
exhaustive in nature and in toto. By so doing the Act accepted standards and procedures for
adoptions between implementing countries that prevents abuses such abduction or sale of
children, ensures proper consent for the adoption, allows for the child’s transfer to the
receiving country, and established the adopted child’s status in the receiving country. 

The act provides the domestic legislation to enable the United States to implement the
provisions of the Hague Convention on Protection of Children and Co-operation in Respect
of Intercountry Adoption (“Convention”). At the same time that Congress passed the
implementing legislation, the Senate was reviewing the Convention. The Senate gave its
consent and approval to the ratification of the Convention on September 20, 2000 23. Although
the Senate approved the ratification of the Convention, the United States has not formally
ratified the Convention. Three months after ratification, the Convention formally goes into
effect. While the implementing legislation has been enacted, there are substantial
administrative responsibilities which must be fulfilled before the United States has fully
complied with the Convention requirements and is ready to ratify the Convention. The
Department of State expects the Convention to enter into force for the United States in 2007.

22
Intercountry Adoption Act, 2000 (USA).
23
‘Intercountry Adoption Act’, International Adoption Help,
https://www.internationaladoptionhelp.com/international_adoption/intercountry_adoption_act.htm (last accessed
17 November 2020).

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4.2: UK

In UK, the provisions of ICA are governed by the Children and Adoption Act, 200624. An Act
to make provision as regards contact with children; to make provision as regards family
assistance orders; to make provision about risk assessments; to make provision as regards
adoptions with a foreign element; and for connected purposes. Part 2 of the Act makes
provision for the Secretary of State to suspend ICA from a country if he has concerns about
the practices there in connection with the adoption of children.

The new Adoption and Children Act 2002 came into force in December 2005, replacing the
Adoption Act 1976 and the Children Act 1989. The new Act modernized the law regarding
adoptive parenting in the UK and international adoption. It also enabled more people to be
considered by the adoption agency as prospective adoptive parents. The new Act also places
the needs of the child being adopted above all else.

Section 1325 of the act makes other provision for the following other matters relating to ICA:
Providing a power for the Secretary of State and the National Assembly for Wales to charge a
fee to adopters or prospective adopters for services provided in relation to ICA; Preventing an
overlap of functions by local authorities where a child is brought into the country for the
purposes of ICA; and Amending section 83 of the Adoption and Children Act 2002 to make it
harder for intercountry adopters to circumvent restrictions on bringing children into the UK.

24
Children and Adoption Act, 2006.
25
Id. s. 13.

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 CHAPTER 5: CHALLENGES FACED AND SUGGESTIONS

5.1 CHALLENGES FACED

Major Challenges faced while dealing with ICA have been discussed under this section, such
as:

 Trafficking and Abuse: The biggest threat to the child in inter-country adoption is
becoming a victim of child trafficking racket. After the domestic procedure for
adoption by the foreign adopting parents is over, it becomes more a question
of international law and international treaties to look after the well-being of the child.
Moreover, the lack of awareness regarding the legal procedures for inter-country
adoption has given rise to many fake adoption agencies. Children are sold abroad by
providing false information about them, falsifying documents, and making use of
loopholes in the adoption guidelines prescribed by the Supreme Court.
 Lack of Institutions to deal with the issue and insufficient Guidelines: CARA
guidelines most often lack the force of law. Hence the parties never really remain
obliged to follow the guidelines or even the Indian law in case the habitual resident
belongs to a country which is not a member or has relinquished its membership from
the convention. The guidelines fail to ensure the health, safety and adjustment of the
child after he/she has left India. It should be noted that as the numbers of adoptions
increase, the number of regulations followed are lesser. The guidelines should have
put a maximum number of adoption procedures a month, by each adoption agency so
that social workers, the authorities, and voluntary coordination committees would not
be overburdened26. 
 Post Adoption negligence: When the child is given for inter-country adoption, post
adoption follow-ups become increasingly difficult. Even though CARA guidelines
outline the role of the Indian diplomatic missions, foreign accredited agencies and
professional social workers in protecting a child from post adoption maltreatment, it
has virtually not helped anyone.
 Post adoption succession: Once the testator dies after bequeathing the property in the
name of the child who had been given in adoption, the identity of the child has to be

26
Palak Jain, ‘Inter Country Adoption’ (2014), Lawtctopus, https://www.lawctopus.com/academike/inter-
country-adoption/#:~:text=International%20and%20regional%20legislative%20framework&text=Inter
%2Dcountry%20adoption%20is%20specifically,ratified%20by%20about%2090%20States (last accessed on 17
November 2020).

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 proved. In cases where there is a challenge to the succession by other survivors, the
procedure becomes even tougher. The country of residence will take the matter as per
the laws of domicile and if such succession becomes legally void due to any
unfortunate mistake, the adopted child would never be able to claim legal rights of the
property and thereby has to suffer great financial, physical and emotional agony.
Unfortunately, India has not entered into any agreement or treaties to solve such
succession matters. The British law still rules the courts in such cases. Every adopted
child develops a strong inclination to know his/ her roots at some point of time. Such
legal turmoil over successions from the biological family may even leave the adoptee
in great frustration.
 Identity crisis: Juvenile Justice Care and Protection (Amended) Act), 2006 specifies
that a child can be adopted by any individual, irrespective of his/her marital status, by
parents who wish to adopt a child of same sex irrespective of the number of living
biological sons or daughters, or by couples who have no children of their own. It has
made adoption a simpler and universal law than the traditional laws. The law is still
tricky, however, in case of inter-country adoptions as prospective foreign parents still
have to first take the role of guardians and take the child to their country. The process
has to be finished there as neither the new law nor any existing law specifically
mentions a procedure in cases of overseas adoption27. 

5.2 SUGGESTIONS

Inter-country adoption has to be dealt with great care as it often opens up floodgates of child
trafficking, child exploitation and sexual harassment of children. The suggestions are:

 CARA guidelines should have two chapters separately dealing with in country and
inter-country adoptions.
 Penal offences must be included in case of any sort of failure by the agencies to
comply with the rules and regulations.
 Licensing procedure for the adoption agencies should be made stricter.

27
K. Lipstein, Adoption in Private International Law: Reflections on the Scope and the Limits of a Convention
(1963), 12 The International and Comparative Law Quarterly (1963).

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  Awareness programs should be arranged for the poor, needy women and parents in
case they want to give their child up for adoption, to go through the correct legal
procedures rather than becoming the victims of touts.
 prevent any risk of children becoming stateless in the inter-country adoption
process, inter alia by ensuring that they will receive the nationality of their adoptive
parents;
 adopt a particularly vigilant approach during and following emergency situations to
prevent potential abuses and violations of international obligations.
 Non-Hague compliant countries should be encouraged to ratify the treaty.
 Professional counselling must be done by a team consisting of recognized child
psychologists, professional social workers and legal practitioners who are familiar
with the international law of the receiving country28.
 The immigration procedure for the adopted child must be done carefully in order to
prevent child trafficking.
 Before the adoption case is opened it should be mandatory to check the bilateral
relationship of the receiving country with India.

28
Judith Masson, ‘Intercountry Adoption: A Global Problem or a Global Solution’, 55(1) Children: Challenges
and Prospects for the New Millennium (2001).

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 CHAPTER 6: CONCLUSION

Inter-country or transnational adoption may become the best option for orphan children to
start a fresh life in a new country. But when the country of domicile for these children does
not have any proper law to show them their destiny, violation of their rights is very much
definite to take place. The country desperately needs better laws and guideline for inter-
country adoption.

The authorities need to ensure thorough checks of every adoption agency to ensure that they
are protecting the child’s rights as has been provided in the constitution and the Juvenile
Justice Care and Protection Act, 2006. Every child has a right to life, home and education. It
is essential that the authorities not only make laws to provide safer transnational adoption to
the children but also to ensure safety of the child even abroad.

It is a common situation in India that the judges dealing with adoption cases, especially in
small towns and cities in India, are not predominantly acquainted with the interpretation of
the inter-country adoption guidelines. Hence, in this regard, a uniform but stringent procedure
must be developed which can be easily followed and observed keeping in regard the human
spirit. As has been seen, Courts, though slowly and steadily, are approaching every possible
dimension of this issue and are laying down norms for eliminating any legal or emotional
havoc for the child or his biological and adoptive parents.

Unless agencies systematically refuse to operate in the framework of systems that are in clear
violation of international norms, they may find themselves complicit in abuses. If prospective
adopters do not receive accurate and dispassionate information on inter-country adoption
needs, they will not be able to adjust their plans and expectations accordingly. Thus, each
actor in the process carries a particular responsibility, and all need to, and must, seek
cooperation with one another to maximize the impact of their efforts.

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