112 LE. EUR L.
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to the parent who has full capacity to perform legal acts, as well as “parental
responsibility“ as defined by Czech law or “rights and duties“ as defined by
Slovak law. Furthermore, the right belongs to the parent only when he ot she is
the legal representative of the chud. Whether the chud is under the direct care
of the parent or not is irrelevant.
To enable adoption, the law requires the consent of both parents as legal
representatives. The consent has to be expressed personally, explicitly and
directly. If the child has both parents, the consent has to be given by both of
them.37 The parent(s) can give speciuic consent to a particular prospective
adopter as well as to an anonymous one (the so-called “blanket consenť‘ or “consent
in blank“). Consent is invalid prior to the birth of the child; the parents are
not allowed to issue their consent until six weeks after the us birth.38
Revocation of consent is permitted, but if the consent is blank, then only before
the chud is passed to the care of prospective adopters.39
Consent of both parents, if they are legal representatives of the chud, is not
required in three cases under the Czech Act on the Family.4° These are as
follows:
1. Lack of interest
The consent of the parents is not later required when for a period of at least
six months the parents have not showed a true interest in the child of the type
parents would have showed.41 In all cases, the
before passing the chud into the pre-adoption temporary care of prospective
adopters.
For a more in-depth diseussion, sec O. PLANKOVÁ, OSVOJENIE DIEtAtA 66 [Adoption
of the Chud], (Bratislava 1979).
38 Art. 68a Czech AF, Art. 119 FGC.
39Art. 68a Czech AF.
° Art. 68 and 68a Czech AF.
41 Art. 68 para. 1 Section a Czech AF. For a critique of the previous
regulation, sec IF. HADBRKA, DOPAD NOREM
RADY EVROPY NA MODERNÍ RODINNÉ
2003] UN. Convention on the Rights oj the ChUd 113
court must eXamine whether the parents have showed a “real interesť‘ in the
chud and whether they are able to take appropriate care of the chud. In flnding
a lack of interest, the court must aiso take into consideration au the
obstacles that prevented the parents fřom showing a trne interest un the chud
and to consider their character. The obstacies can be obj ective, subj ective
or even “speculative“ ones aimed at preventing the prospective adoption.
Furthermore, the court must also eXamine the conduct and actions of the parents
toward consoiidating their personal, family, social and living conditions to be
able to take personal care ofthe chud.42
2. Absolute lack of interest
The consent of the parents Is not later required when for a period of at least
two months after the chud‘ s birth the parents have showed absolutely no
interest in the chud, although no grave obstacle had prevented them from
showing such interest.43 The term “absoiute lack of interesť‘ was introduced
into the Czech Act on the Family by the Great Amendment to the Act (1998). The
new provision was passed as a reaction by the legislature to long-lasting calls
by practicing lawyers for an effective law. The amendment helps to resolve the
iegal status of newly-born and abandoned children in as shon a time as
possible. The period oftwo months has to elapse after the child‘s birth.44
3. The “blanket consenť‘ (consent in blank)
The consent of the parents is not later required, when they have already expressed
their consent “in advance,“ regardless of any specific future adopter.45 The
consent to the adoption has to be given by the parents in advance (before
initiating the court proceeding for
PRÁVO 516 [The Impact of the Norms of the Council of Europe on Modem Family
Law], (Právní praxe 1994, No. 9).
42k1.
Art. 68 para. 1 Section 1, Czech AF.
Id.
Art. 68a Czech AF, Art. 1192 FGC.
114 J.E. EuR.L.
[Vol. 10:1
adoption). The parents baye to be physically present before either the court or
the body of social-legal protection of the chud. The Great Amendment
establishes a strict condition for blanket consent regarding newbom children.
In accordance with the Buropean Convention on the Adoption of Children, the
amendment provides that the consent of the parents who are the child‘s legal
representatives will not be accepted until the chud is six weeks old.46 The new
provision aims to protect both the newborn child‘s mother in a difficult
situation and the child‘s right to be brought tip in bis/her natural family.
The (ireat Amendment introduced an improvement to the legal status of the minor
parent even if he/she is not the legal representative of the chud.47 The new
law provides that the consent of the minor parent is required for adoption of
the child.48 The tests of lack of interest, absolute lack of interest and
blanket consent apply even if the parent is minor,49
The Great Amendment also effeeted an improvement to the legal status of the
so-called “probable“ parent. The man who declares that he is the father of the
child is allowed to initiate a court procedure in order to determine bis
fatherhood.5° In addition, the legal status of the biological father has been
improved by the new concept on adoption. According to the new Article ‘70a of
the Czech Act on the Family, the adoption of the child camiot be granted before
the court‘ s decision in the proceeding on fatherhood becomes effective.51
46 ActNo. 91/1998 Coll.
The legal position of the minor parent was vely weak for a long time in both
the Czech Repub lic and Slovakia. The courts treated minor parents as
“participants“ in hearings and their view was eonsidered only when they
exereisd proper personal care of the chud and where there were no cireumstances
warranting depriving them of parental responsibility.
48 Art. 67 pan. 2 Czech AF; since 1998, there Is no age limit.
Art. 68 para. 2 Czech AF.
50 Section 3 ofthe amended Art. 54 para. 1 Czech AF.
This provision of the amendment was influenced not only by practical and
theoretical considerations, but especially by Strasbourg case law. See J. HADERKA, PŘÍPAD KEEGAN VERSUS IRSKO 311-313 [Case
Keegan Versus Ireland].
2003]
UN C‘onvention on the Rights oj the Chud 115
In applying tbc tests of lack of
interest, absolute lack of interest and blanket consent, the court must examine
au the surrounding circumstances In a special hearing (called “incidental
proceeding“). This special procedure aims at determining whether the chud is
legally available for adoption or not. The court has to resolve the
above-mentioned matters before the prospective adopter applies for the
adoption.52
PinaRy, In the case of blanket consent, the revocation of the parents‘ consent
is allowed only before passing the chud to the care of prospective adopters.53
Nevertheless, there is no regulation of revocation in general in the Czech
Republic. Both the doctrine and the court practice follow the view that revocation
of consent is possible until the adoption becomes defnitive.
The Slovak Act on the Family uses only the tests of lack of interest and
blanket consent.54
B. The Ben Interest oj the Chud
Both the Czech and Slovak Acts on Family
impose a daty on the court to examine the state of health of the chud and
communicate its fndings both to the pro spective adapter and the legal
representatíves of the chud. The court requests a health report Iiom an expert
on both the physical and mental state of the chud, including a prognosis.
However, the ínterpretation of this provision should not lead to
“discrimination“ of handicapped (disabled) children. Particularly difňcult in
this area are probletns caused by hereditary diseases or the HIV virus.
C. The Consent of tbc Minor Chud
Both the Czech and Slovak Acts on Family
formulate this condition as follows: “consent is necessary when the child is
capable of perceiving the effects of adoption, unless the purpose of adoption
52 Art. 68 pata. 3 Czech AF.
Art. 68a Czech AF.
54Art 68 Slovak AF.
116 JE. EUR. L.
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would be thereby Mistrated.“55 The interpretation of this provision has been
rather difficult. In practice, this article is often applied, for instance,
when the chud has been living in a foster family since bis eariy years and has
not known the original parents and when the foster parents seek to exchange
foster care for adoption. In this context, the so-caiied “participation“ rights
of the chud grounded in the Convention on the Rights of the Chud aiso have to
be considered. According to these rights, a chud who is capable of forming
his/her own views has the right to express those views Ůeely in au matters
affecting the chud and these views are given due weight in accordance with the
age and maturity of the chud. For this purpose, the Convention provides that
the chud shali be given the opportunity to be heard in any judicial and
administrative proceedins affecting the chud, either directly ot through a
representative or an appropriate body, in a maimer consistent with the
procedural rules of national law.56 The paraphrased equivalent of the
above-described conventionai participation rights has been introduced recently
into the Czech Act on the Family.57
Neither Czech nor Slovak law establish any age limits for a legal act exercised
by minor children.58 Finally, it should be added that there is no principle of
anonymity of adoption designated in Czech and Slovak law.
Art. 67 para. 1 Czech and Slovak AF.
56CRCArt. 12.
57See
new Art. 31 para. 3 AF.
European laws regulate this issue differently. The Austrian Civil Code (ABGB,
Art. 181) recognizes the child‘s “right to be heard“ when the minimum age is
five years. According to the French Code Civil (CC, Art. 345), a child older
than thirteen years always has to agree personally to adoption. The German
Civil Code (B GB, Art. 1746) establishes the age of fourteen years for
considering the ehild‘s opinion on the adoption. The Dutch law provides the
ehild‘s “veto“ on the intended adoption when he/she is tifteen years old.
ľ.
2003]
UN Convention on the
Rights ofthe chud 117
D. Eligible and Suitable Prospective Adopter and HisĺHer Will to
Adopt the Child
The personality of the prospective adopter
plays an essential role in adoption. This S so
because it depends greatly on the adoptive parent whether the adoption will be
successful and in the best interest of the chud. That is why it is necessary to
eXamine not only bis/her desire to adopt the child hut also bis/her character,
personal dispositions, motivation for adoption, life style and other
cireumstances (finances, property, dwelling, etc.). The prospective adopter
should ensure a stable and harmonious environment for the ehild and hisfher
growth.
Both the Czech and Slovak doctrine and practice follow the view that there
should not already exist a family relationship between the chud and the
prospective adopters that would render adoption needless. This pre-condition is
not establisbed by the law, hut is a consequence of the nature of adoption.
Generally, it is thought that adoption is not possible between first-degree
relatives and between siblings.
Furthermore, the prospective adopter must be an adult and have full capacity to
perform legal acts in order to be able to eXercise the role of legal
representative of the child and protect au
his/her interests.
The Aet on the Family in both the Czech Republic and Slovakia lays down expressis
verbis that the court has to examine the
physičal health of the prospective adopter (relying on the medical reports and
“other necessary investigations“) and to determine whether it is not
detrimental to the aim of adoption.59 The health of the prospective adopter
Řhould be good enough so that heJshe eould provide the child with a
long-lasting and generally suitable family environment. The prospective adopter
should be able to become a supporter, educator and role model for the child.
The court has the duty to inform the prospective adopter and the legal
representatives of the child of its findings regarding the health of the adopter.
Art.
70 Czech and Slovak AF.
118 J.B.EuR.L.
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The Act on the Family In both countries provides that the chud can be jointly
adopted oniy by persons married to each other.6° The husband and wife are.
ailowed to adopt the chud simuitaneously or successively. In such cases, the
court must eXamine the length of the marriage, its course and “quality,“61 as
well as other conditions and aspects. Even if only one spouse is to adopt the
chud, both the Czech and Slovak Acts require the consent of the spouse of the
adopter. This condition has to be met even In the Case where the couple are not
living together. The consent of the spouse of the adopter is not required where
the spouse does not have full capacity to perform legal acts or where consent
is prevented by an obstacie “difficult to overcome.“62
The law In both countries aiso provides that there has to be an adequate
difference in age between the prospective adopter and the chud.63 At the same
time, the Acts on the Family do not establish any age categories or any age
limits.M However, both the doctrine and the legal practice interpret the term
“adequate difference in age“
60Art 66 para. 1 Czech and Slovak AF.
61 Compare
Ast. 9.2 b), c) of ECAC, which makes joint adoption available only to spouses.
Some laws even demand a certain minimal period of matrimony — for instance, the French law flxes the minimum period
of matrimony at five years.
62 Art.
66 para. 2 Czech and Slovak AF.
63Art. 65 para. 1 Czech and Slovak AF.
64 Compare
the traditional Austrian Civil Code (ABGB, 1811) where the adopters had to be
older than forty and the adopted child had to be at least eighteeú years their
junior (Art. 180).
ECA Children provides that the adopter has to reaeh a minimum age prescrihed
for this purpose, this age being “neither lower than twenty-one years nor
higher than thirty-five years.“ Article 7 para 1. There are, of course,
exceptions for the husband of the child‘s mother and in other exceptional
circumstances. As mentioned above, the Czech Republic had made a reservation
not to apply this article. For a discussion of problems in this area, see L.
Macháčková, Náhradní rodiče ve vyšším věku - diskriminace v zá koně o rodině? [Older
Substitute Parents -
Discrimination in the Act of the
Family?), 8 PRÁvo A RODINA 8 (2000).
..:
..
‚H
2003]
UN. Convention on the Rights oj the
Chud 119
to mean the usual difference in age between natural parents and their
children.65
The Czech and Slovak legal treatises use the term “step-parent adoption“ when
the chud is adopted by the new spouse of one of bis/her parents (the
stepfather/mother). This form of adoption does not provide the chud with a “new
family“ but, in fact, harmonizes the de facto relationship with the legal one.
Nevertheless, this kind of adoption is considered a “full adoption.“
E. Obligatozy Pre-adoption Temporaíy Care
In order to ensure that the adoption will be
in the best interest of the child both the Czech and the Slovak Act on the
Family provide that the chud is to live under the care and support of the
prospective adopter for at least a three-month period preceding the court‘s
decision on the adoption.66 Since the institution of pre-adoption care is
focused on creating a relationship between the prospective adopter and the
chud, the new “family“ is provided with this period to prove its suitability.
The tbree months are aimed at giving both parties a chance to get to know each
other in order to prevent a possible revocation of the adoption in the future.
F. Additional Conditions Fixed for Irrevocable Adoption
Since it is not possible to revoke the
irrevocable adoption, the law in the both Czech Republic and Slovakia imposes
additional requirements for irrevocable adoptions. These are as follows:
1. Only a chud older than one year can be adopíed by irrevocable adoption.67
The rationale of this requirement is that once the chud reaches the age of at
least one year it is
65
See Judgment of the Czech Supreme Court No. 49/1976; compare Art.
8 of the European Convention on the Adoption of Children.
Art. 69 Czech and Slovak AF. Compare the Dutch and French laws, which regulate
obligatory temporary pre-adoptive care more strictly (the Netherlands: one
year, France: 6 months).
67Art. 75 Czech and Slovak AF.
120 J.E. EUR. L.
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possible to set up a prognosis for bis/her development,
especially as far as health is concerned.
A particularity of Czech law is that irrevocable adoption is available
primarily to spouses, to the spouse of the chud‘ s parent, to the spouse of the
chud‘ s dead parent or to the spouse of the child‘s adopter.68 The one
exception is that a single person can adopt a chud only if it can be shown that
the adoption will be in the best interest ofthe chud.69
2. Article ‘74 of both acts requires entry of the adoption into the vital
register (public records). The chud will obtain a new “list of birth“ with the
narnes of the adopters as his/her parents and without either the fact of
adoption or the identity of his/her former parents listed.70
According to the new legal regulation of vital registers in the Czech
Republic,7‘ and un accordance with international standards, the public record
should be kept in such a way as to prevent persons who do not have a legitimate
interest 1om leaming the fact that a person has been adopted or the identity of
his/her former .parents.72 Nevertheless, following the Convention on the Right
of the Chud, which guarantees the right of the chud to know bis/her parents,73 the
Czech law regulating public records gives the chud who has reached the age of
eighteen the right to inspect all facts recorded un vital registers. This means
that the adopted child has a legal claim to know bis/her origin and the names
of bis/her original (natural) parents.
68Ast.l4Para2CzechAF.
69 Art.
74 Para 2 Czech AF.
70 This
is in accordance with para. 3 of the European Convention on the
Adoption of Children.
71 Act.
No. 30 1/2000 Coll. dealing with vital registers, names and surnames.
72 In
accordance with Art. 20 para. 4 of European Convention on the Adoption
of Children.
73CRCArt.lpara. 1.
. :
..
F.
2003] UN C‘onvention on the Rights oj the ChUd 121
IV. ADOPTION
PROCEEDINGS
The legal regulation of the institution of adoption and of adoption by
administrative and judiciäl proceeding has seen a significant number Of changes
since the signing and rati1‘ing Of the international conventions in the Czech Republic
and Slovakia.
Adoption can be granted only by court in the Czech Republic and Slovakia.
Furthermore, hi the Czech Republic, a special administrative
“proceeding“ before “the authorities of social-legal protection ofthe chud“ has
to prccede the court‘s decision. The legal relationship between the two bodies
is regulated mainly by the new Act on Social-Legal Protection of Children74 and
iii accordance with the international conventions discussed above. The special
proceeding (called “co-operation“) concentrates on the mutual suitability of
the chud and the adopter.75 The procedure can be started only on the basis of
application of the person seeking to become the adopter. He/she has to apply to
the District Authority, which keeps all the documentation on the children and
prospective adopters. The District Authority then passes on a copy of the
documents to the Miiistry of Labor and Social Policy. The Ministry keeps the
so-called “central records“ which contain, in addition to the documents passed
by the District Authority, the expert opinions and the child‘s opinion obtained
by the Ministry before starting their own proceeding — searching for a mutually suitable “pair.“
When the suitable “paiť‘ is found, the prospective adopter has the right to get
to know the child and to be granted “obligatory :pre adoption temporary care.“
The prospective adopter is allowed to submit its application for adoption to
the court only after the three months have elapsed.76
As regards inter-country adoption, the Hague Convention on Protection of
Children and Co-operation in Respect of Intercountry Adoption (“CPC“) is the
main legal regulator used in both countries.
ActNo. 359/1999 Coll..
751d. Art. 20 ff.
76 Art. 69 Czech and Slovak AF.
122 J.E. EUR. L.
[VoL 10:1
According to Article 14-22 of the CPC, the adoption proceeding is started when the
prospective adopter applies to the central autority in the State of his/her
habitual residence. If the central authority is satisfied that the applicant is
eligible and suitable to adopt, it shall prepare a report and transmit it to
the central authority of the State of the child‘s origin. The report shall
include information about the applicant‘ s identity, eligibility and suitability
to adopt, background, family and medical history, social environment, reasons
for adoption, ability to undertake an inter-country adoption, as well as
characteristics of the child for whom he/she would be qualiňed to care. If the
central authority of the State of the child‘s origin is satisfied tat the child
is adoptable, it shall transmit its report on the chud to the central autority
of the applicant, proof that the necessary consents have been obtained and the
reasons for its determination on the placement, taking care not to reveal the
identity of the mother and the fater if, in the State of origin, these
identities may not be disclosed. Both central authorities shall take all
necessary steps to obtain permission for the child to leave the State of origin
and to enter and reside permanently in the receiving State.77
The Office of International Legal Protection of Children (Úřad pro
mezinárodněprávní ochranu dětí) is the Central Authority in the Czech Republic
(in Brno) under the CPC and the new Act on SocialLegal Protection of Children.
Before the new Act, there existed no such legal regulation in the country,
although the Ministry of Labor and Social Policy equent1y approved
inter-country adoptions for children placed in institutional care in the Czech
Republic.78 Currently, the Oftice of International Legal Protection of Children
follows the international conventions and mediates adoption abroad only when
the children cannot be adopted or placed in foster families in the State of
origin (i.e. the Czech Republic.) The Offlce aims to ensure that inter-country
adoption is only an alternative solution and that the best interest of the chud
and his/her fundamental rights aře primary considerations, thus preventing
abduction or trafficking in children. If intercountry adoption is suitable, a
special proceeding is
CPC Art. 14-22.
78 On the Czech eXperience with inter-country adoption,
see an article by the direetor of the Office of International Lega! Proteetion
of Chiklren, R. Záleský, Realizace
mezinárodního osvojení, [Achieving
inter-country adoption], 2
NÁHRADNÍ RODINNÁ PÉČE 9 (2001).
2003] UN. C‘onvention on the Rights ofthe Chud 123
started according to administrative rules. Nevertheless, adoption is to be
granted by the court abroad in the state of the habitual residence of
prospective adopters, as it is not in the jurisdiction of the courts of the
Czech Republic.79 The reverse applies when a chud from abroad is to be adopted
in the Czech Republic.
The Centre for International Legal Protection of Children and Youth (Centrum
pre medzinárodno-právnu ochranu deti a mládeže) is the Central Authority in
Slovakia (Bratislava) undcr the CPC.
Finally, adoption itself is granted by
the court on the motion of the prospcctive adopter in both countries. The
future adopter (or adopters—spouses), the child that is to be adopted and
his/her parents (but only when their consent to the adoption is required) are
participants in the court proceedings. The child has to bc represented by a
custodian.
The court proceeding is regulated by the former Czechoslovak Federal Republic‘s
Act on Civil Judicial Order8° in both the Czech Republic and Slovakia.
V. EFFECTS
OF ADOPTION
As it has already been discussed, the main effect of adoption in the Czech
Republic and Slovakia is the “total incorporation“ of the minor chud into a new
adoptive family.
According to the Czech Act on the Family and the Slovak Act on the Family, the
chud obtains the same rights in the new family as if he/she were bon there,
including rights in law of successión. The adopters in the Czech Republic will
assume “parental responsibility“ and will be legal representatives of the chud.
Similarly, the adopters in Slovakia will have “parental rights and duties“ and
will become legal representatives of the chud as well. The adopters in both
countries have to providc support for the child, and the child acquires “eX
lege“ the sumame of the adopter or the spouses-adopters.
See Art. 41 of the Act No. 97/1963 Coll. on international private and
procedural law.
80 Act No. 99/1963 Coll., Art. 181-185.
124 LE. EUR. L. [Vol. 10:1
The first name of the ehud catmot be ehanged in the court proceedings in either
the Czech Republic or Slovakia. However, the new Czech law regulating publie
records and names and surnames makes it possible for the adopters to choose a
new name for the adopted ehud in substitution for, or In addition
to, his own within a period of SiX months
after the date when the court decision became effective.8‘ A chud older than
fifteen years must be counseled.
An effect of irrevocable adoption under both the Czech and the Slovak law is
that the name of the adopter (or spouses-adopters) replaees the name of the
chud‘ s natural parents In the vital register. The chud is then given new legal
doeuments.
The adopted chud acquires the citizenship of the Czech Republic provided that
at kast one of the adopters is the state citizen of the Czech Republic, which
follows fřom international conventions.82
VI. REVOCATION OF ADOPTION
The institution of adoption under the
laws of the Czech Republic and Slovakia is understood — with the exception of limited adoption
— to be a “fíction“ imitating the biological
relationship. That Is why it does not cease to eXist either when the child
reaches the age of maturity or at death (inheritance law is then applied).
Instead, the institution of adoption is generally considered an institution of
long-lasting or permanent substitute famuly care. The new legal regulation of
“co-operation“ and striet selection of future adopters aims to prevent crises
in such new families. The court is allowed to revoke the adoption only on
serious grounds, when such a harmonious relationship between the adopter(s) and
the chud a normally eXists between natural parents and children has not been
‚ In the Czeeh Republic, the new An. No. 301/2000 Coll. dealing with vital registers, names and surnames
allows the adoptive parents to choose both another natne or an additional natne
for the ehud.
82 As for
determining the citizenship of
the adopter, see Act Na 40/1993 Coll. on gaining and losing eitizenship of the
Czeeh Republic.
2003] UN. Convention on the Rights oj the Chud 125
established.83 The reasons for revocation of adoption may be on the part of the
adoptive parents as well as the adopted chud. The revocation has legal
consequences “eX nunc.“ Nevertheless, the effect of revocation is that the ehud
legally returns to the family of bis/her origin. The “old“ rights and duties in
this natural family are “re-established,“ including maintenance duty and rights
tom inheritance law. The surname ofthe chud will be changed as well.
VIL CoNcLusIoN
The institution of adoption was viewed by the former socialist law 1iom the
perspective of the minor chud. Although evep today there are some caus for
enabling adoption of adult persons, it is not likely that the present
“traditional concepť‘ of adoption will be abandoned in the re-codified Czech
and Slovak family law. As it was described above this institution serves the
best interest of the minor child, who is mostly abandoned or an orphan, and
aims to become a “definitive“ solution of the child‘ s critical situation.
It is necessary to emphasize that the Czech Republic and Slovakia baye
harmonized their national laws of adoption witb high international standards,
first of all by signing and rati‘ing the abovementioned international
conventions and by passing a significant number of acts and amendments to the
existing ones. According to the main tenets of these laws, the child has the
constitutional right to be raised in an atmosphere of happiness, love and
understanding in bis/her own family. Only when the environment ofthe chuld‘s
origin is inappropriate, unavailable, hostile or missing should the
institutions of substitute family care apply.84 Bach form of substitute family
care should then be oriented to the child‘s welfare.
83 Thus, it is no longer possible under Czech law to
cancel the adoption by a contract made by adopters and adult chud. See note 3, injra.
84
In both the Czech Republic and Slovakia
the following institutions of substitute care are regulated:
1. Collective care: Institutional care (both Czech and Slovak AF); hstitutional
protective care (Criminal codes)
2. Family care: Adoption (both Czech and Slovak AF); Foster care (Czech
AF, Slovak Foster Care Act); Care exercised by the third person (both
Czech and Slovak AF); (Juardianship (Czech AF) and custody (Slovak
AF)
126 LE. BULL.
[Vol. 10:1
For more details, see M. HRUŠÁK0vÁ, Z. KRÁLÍČKOVÁ: ČESJ(É RODINNÉ rtkvo
[Czeeh Family Law] (2d ed., MU and Doplněk 2001) and generally HRuŠÁIC0vÁ, supra note
33.
126 J.E. EUR. L.
[Vol. 10:1
For more details, see M. HRuŠÁK0vÁ, Z. KRÁLÍČKOVÁ: ČESIÉ RODINNÉ itkvo [Czeeh
Family Law] (2d cd., MU and Doplněk 2001) and generally HRUŠÁKOVÁ, supra note
33.