@article{oai:chuo-u.repo.nii.ac.jp:00012774, author = {ŁUKASIEWICZ, Jakub M.}, issue = {4}, journal = {比較法雑誌}, month = {Mar}, note = {application/pdf, This article analyzes the relationship between registration of parenthood and parental authority in Polish family law. In addition, it considers the connection between registration of parenthood and parental responsibility under English family law. Polish family law is based on a rather conservative axiology. The institution of parental authority is always associated with kinship or adoption. Surrogate agreements are prohibited, and parents must be of different genders. The English conception of parental responsibility is more liberal. It does not always depend on kinship or adoption. Substitute motherhood is allowed as is parenthood for persons of the same sex. The contrast between these two systems shows that shared values (such as the basic principle of acting for the good of the child) may be perceived differently depending on the historical, cultural, and moral context.}, pages = {31--67}, title = {The Legal Position of a Child in Polish Family Law and English Family Law}, volume = {53}, year = {2020} }