The making of an adoption order creates a 'family life'1 between a child and his adoptive parents2, and where an adoption order has been made by the courts 'family life' will exist regardless of whether the child and the adoptive parents have actually established de facto ties3. Failure to give full recognition to a foreign adoption order where de facto ties exist between the adoptive mother and the child will give rise to a breach of Article 84. The refusal to convert an Islamic kafala into a civil law adoption has been held not to violate Article 85.
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