When the Indian Supreme Court delivered a verdict recently allowing Indian Muslims to adopt a child, the discussion invariably shifted to the global debate on integrating Islamic values with other belief systems, and how laws need to be administered in the melting pot of a multi-religious society.

Adoption is a good test case to examine in depth because among the many myths followers of Islam have to deal with is the widely held belief that adoption is not allowed in the religion.

Adoption is too important an issue to restrict to convenient news bytes and requires a deeper analysis to bring out the prevailing picture.

Perceptions of Parenthood

Since definitions tend to influence thinking, the first thing to understand is that the closest comparable description to the western practice of adoption in Islam is termed kafala, quite literally "to feed." What it really defines is a foster child-parent relationship which has origins in charity and in providing a family to children who have been orphaned.

The fundamental difference from western practice is that even if a Muslim family "adopts" a child they are obliged under the religion to keep the original family name and acknowledge the familial line, instead of transposing the new identity, which is what commonly happens in the West. Islamic scholars quote the Koran's relevant verse in this regard,

"Nor has He made your adopted sons your (biological) sons. Such is (only) your (manner of) speech by your mouths. But Allah tells (you) the Truth, and He shows the (right) Way. Call them by (the names of) their fathers; that is juster in the sight of Allah. But if you know not their father's (names, call them) your brothers in faith, or your trustees. But there is no blame on you if you make a mistake therein. (What counts is) the intention of your hearts. And Allah is Oft-Returning, Most Merciful."

The rationale behind this stand is that the principle of truth should not be violated by denying the adopted child his original name or his family origins.

The issue of lineage is certainly a vexed one. In certain cultures and religions, more emphasis is given on matters of lineage than in other societies. However the West is certainly no stranger to such beliefs, take the case of Lutheran Iceland and their fixation with how children are named.

Inheritance Imbroglio

Lineage of course has some practical implications as well--especially when it comes to a child inheriting the property and other wealth of his or her parents. Critics of Islamic practices on adoption frequently state that an adopted child has no legal right of inheritance, unlike in Western societies.

While this is correct in purely technical terms, it ignores two important ground realities. One, under Islamic law, Muslims have the right to bequeath upto one-third of their estate to a non-inheritor. In a family of four children where one is adopted it could even mean the adopted child getting a larger share than the biological offspring.

Two, since the adopted child is not asked to relinquish ties with his original family, he or she can gain from any inheritance provided by them, and this includes the larger extended family--a common feature of many Islamic societies.

The Secular Supposition

In a Utopian world, all religions should be able to harmonize themselves to a single standard to ensure everyone is treated equally. The trouble with all Utopian ideals is in the "how."

Many believe that secularism is the way to achieve this, but there are two distinct strains of secularism that have appeared. One approach is that the state should be separate from religion, to the extent that no politician should associate themselves with any religious event or discussion. That seems to echo back to the days of Communism.

The other approach is that the state associates equally with all religions and gives each religion its due. The challenge here is that does "equal" connotate proportionality (and thus breed majoritarianism)? And in giving each religion its space, what happens if it runs into conflict with other aspects of a state's constitutional guarantees to an individual?

While the Indian Supreme Court judgement is an example of such a dilemma, it is by no means the only one. Just this year, a Catholic Church run adoption agency in Scotland lost its charity status because it denied adoption to same-sex couples. It later won an appeal. While religious groups can often discriminate, it must also be recognized that the same religious groups actively promote adoption of orphan kids, giving them safety, education, and an opportunity to become valuable members of society.

It's therefore a tough balancing act for secular governments to determine whether these religious groups are harming or benefiting the worthy cause of adoption in the big picture.

Secular Data

Rather than reinforce stereotypes it's useful to determine through a dispassionate analysis of data how Islam has been faring on the adoption front and whether "secular" perspectives and Islamic values are in sync or not.

In a study conducted by the UN between 1999 and 2005 to determine the countries with the largest number of adoptions there were some unsurprising names-- the US topped the list, followed by China, and then Russia. Ranked 9th in domestic adoptions though was Kazakhstan--a "secular" state but where Muslims were the largest group (47 percent). Both single men and women are able to adopt in the country and the child must consent to be adopted if aged 10 years or older.

Ranked 8th in domestic adoptions was Uzbekistan--also a secular state but with an even higher proportion of Muslims, accounting for almost 90 percent of the population. It grants almost similar privileges and protections for adoption as Kazakhstan. India, where demands for a "uniform civil code" were raised piggybacking on the Supreme Court judgment is ranked 12th in domestic adoption.