A COMPARATIVE STUDY OF CHILD CUSTODY SYSTEMS IN DIVORCE CASES INVOLVING MINOR CHILDREN IN CHINA AND UZBEKISTAN

This study presents a comparative analysis of the child custody systems applicable to divorce cases involving minor children in the People's Republic of China and the Republic of Uzbekistan. The research examines the legal principles, legislative framework, and judicial approaches governing the determination of child custody after divorce in both jurisdictions. Particular attention is devoted to the implementation of the principle of the best interests of the child, the allocation of parental rights and responsibilities, and the role of courts in resolving custody disputes. The study employs comparative legal analysis, doctrinal research, and the examination of national legislation, international legal instruments, judicial interpretations, and relevant academic literature. The analysis demonstrates that both China and Uzbekistan recognize the paramount importance of protecting children's rights and welfare in custody proceedings and have incorporated the principle of the best interests of the child into their legal systems. At the same time, notable differences exist in the legislative regulation, judicial practice, and procedural mechanisms governing custody determination. Based on the comparative findings, the study identifies legal approaches that may contribute to the further improvement of child custody regulation, particularly with respect to strengthening child-centered decision-making, enhancing judicial consistency, and ensuring more effective protection of the rights and interests of minor children in divorce proceedings. The findings contribute to the comparative study of family law and provide practical recommendations for the continued development of child custody legislation in both countries.