The nobility of the Germanic, Celtic, and Slavic cultures that dominated Europe after the decline of the Roman Empire denounced the practice of adoption.[15] In medieval society, bloodlines were paramount; a ruling dynasty lacking a "natural-born" heir apparent was replaced, a stark contrast to Roman traditions. The evolution of European law reflects this aversion to adoption. English Common Law, for instance, did not permit adoption since it contradicted the customary rules of inheritance. In the same vein, France's Napoleonic Code made adoption difficult, requiring adopters to be over the age of 50, sterile, older than the adopted person by at least 15 years, and to have fostered the adoptee for at least six years.[16] Some adoptions continued to occur, however, but became informal, based on ad hoc contracts. For example, in the year 737, in a charter from the town of Lucca, three adoptees were made heirs to an estate. Like other contemporary arrangements, the agreement stressed the responsibility of the adopted rather than adopter, focusing on the fact that, under the contract, the adoptive father was meant to be cared for in his old age; an idea that is similar to the conceptions of adoption under Roman law.[17]
Attitudes and laws regarding adoption vary greatly. Whereas all cultures make arrangements whereby children whose birth parents are unavailable to rear them can be brought up by others, not all cultures have the concept of adoption, that is treating unrelated children as equivalent to biological children of the adoptive parents. Under Islamic Law, for example, adopted children must keep their original surname to be identified with blood relations,[194] and, traditionally, women wear a hijab in the presence of males in their adoptive households. In Egypt, these cultural distinctions have led to making adoption illegal.[195]
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