For example, the Saskatchewan court of appeal in Burnfiel v. Burnfiel 1926 CanLII 113 (SK CA), [1926] 1 WWR 657, 20 Sask LR 107, reversing 1925 CanLII 249 (SK QB), [1925] 2 WWR 629, held that a person adopted in a jurisdiction recognizing adoption cannot claim the status of a “child” in a jurisdiction not recognizing adoption so as to claim to inherit property situate within the latter jurisdiction. Haultain, C.J.S. states at pp. 662-3: “An adopted child is an artificial creature unknown to our law. He is not a ‘child’ in any sense of that term as used in our law. In his case we have to look to the law of the domicile of adoption to ascertain the rights of succession attached to that relationship, a relationship which our law does not acknowledge, and to which under our law no rights are attached. “In the case of a legitimated child, he comes into this province with a recognized status to which certain rights are attached under the law of this province.”
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