CONTRASTING LEGAL CONCEPTIONS OF FAMILY OBLIGATION AND FINANCIAL RECIPROCITY IN THE SUPPORT OF OLDER-PEOPLE - FRANCE AND ENGLAND

This paper explores the way family obligation and reciprocity are defi ned in law in France and England. Focusing on the areas of inheritance and financial support in relation to older people, it explores how th ese are contrasted and linked in the two societies. In France, familie s are legally obliged to support their kin through obligation alimenta ire, but inheritance is secured by law within the family. In England b y contrast there is no such legal obligation to support older relative s; nor is there any constraint on inheritance: testamentary freedom is the legal principle. The paper discusses the significance of these di fferences and assesses how far they are modified by the operation of t he welfare state and by embedded assumptions about family relations. I t sets the differences within the context of different discourses of l aw and social policy in the two countries.