Living in limbo: In Malaysia, adopted children are not guaranteed citizenship

In Malaysia, the citizenship of a person is determined by the principles of jus soli and jus sanguinis. Jus soli, which is Latin for “right of the soil”, indicates that citizenship is determined by the birthplace of a person. Jus sanguinis, which means “right of blood”, is a principle whereby citizenship follows one or both parents who are citizens of the state.

With regards to the law governing adoption, there exists two parallel systems in Malaysia, one governing the adoption of Muslim children and the other of non-Muslim children. The adoption of non-Muslim children is governed by the Adoption Act 1952 while the adoption of Muslim children is governed by the Registration of Adoptions Act 1952 and Syariah laws.