مطالعه تطبیقی حضانت در نظام حقوقی ایران و سوعد

Abstract This comparative study examines the laws and practices governing child custody in Iran and Sweden. Both legal systems consider the best interests of the child as a central principle in judicial decision-making. However, the approaches and implementation mechanisms of this principle differ significantly. While Iran traditionally adheres to a sole custody model influenced by cultural and religious factors, Sweden emphasizes joint custody and equal parental participation. Through an in-depth analysis of the laws and practices in both countries, this study explores the factors contributing to these differences, including the role of religion, the age of maturity, and the child's participation in decision-making. The findings indicate that cultural, social, and legal differences significantly impact child custody laws and practices in the two countries, ultimately affecting children's well-being and future. Additionally, this study offers recommendations for improving child custody laws in Iran, such as strengthening the role of child legal advisors, promoting joint custody, establishing strong supervisory mechanisms, and educating parents. Keywords: Child custody, Iran, Sweden, Best interests of the child, Sole custody, Joint custody, Cultural influence, Role of religion.

مطالعه تطبیقی حضانت در نظام حقوقی ایران و سوعد Keywords:

حضانت کودک , حضانت تک والدی , تاثیر فرهنگ