Dr. Andrea Mulligan:

The first thing I will say is that there is ongoing litigation concerning adoption in surrogacy, which I am involved in. I cannot, therefore, make any comments broadly about that. What I will say in terms of the European Court of Human Rights, ECHR, case law is that the ECHR said the mother has to be recognised and that can be done via adoption. I suppose, therefore, that is relevant in terms of international obligations.