Guardianship Laws of Minor in India and Western Countries: A Comparative Exploration

Abstract

This research is a comparative study of the provisions for guardianship and custody. In law the emphasis is on the law of India, UK and USA. The purpose of this research is to analyze the provisions of guardianship, custody applicable to these legal systems. The analysis is divided as follows: Guardianship and custody laws of Hindus, Muslims and Christians. The objective is to highlight the similarities and differences between the provisions of these legal systems and to come up with the conclusion whether the one is more favorable than the other in catering for the needs and interests of its subjects which legal system caters for the interests of its subjects? Which legal system protects the interests of the child best? Having come to that conclusion, the researcher aims at indicating laws which should be considered for reform.

Keywords: minor, guardianship, western