Document Type


Publication Date



The legal response to child maltreatment-or the risk of child maltreatment-varies greatly from society to society and has been little studied, in part because of the idiosyncrasies of community values, social organization, history and legal traditions.2 Cross-country comparison of child abuse and neglect is especially difficult because the ambiguity of social standards and the imprecision of terms used makes it difficult to define the specific behavior one is studying. Even though child maltreatment is widely prohibited, the definition of what actually constitutes child abuse and neglect is not clear within a particular country, much less uniform from one society to another.3 This article tries to avoid some of the difficulties of cross-country comparisons by examining the child protection legal process of jurisdictions that share relatively similar social values and a common language-the United States, England and Wales, and Scotland.