A comparative study of Elderly Care Acts of India, Sri Lanka, and Bangladesh: policy learning for other countries Open Access

The world is witnessing two significant trends in the current demographic landscape: a decrease in the death rate and an increase in the elderly population (He et al., 2016). These changes become concerning when the growing elderly population strains the capacity of many developing states. While economically developed countries have long established social welfare policies and institutional arrangements for the elderly (Lee and Mason, 2011), developing countries must strike a balance between the limited capacities of states and the growing needs of elderly people. Many countries have addressed the rights and care of the elderly through different policies, but these initiatives fall short in meeting the wave of indigent elderly people and their diverse needs (Mégret, 2011). As a result, countries have adopted strategies to balance the responsibilities of the state and the families towards their elderly by enacting elder care and/or filial care acts (Ting and Woo, 2009). These acts have shifted some of the duties of elderly care towards families and adult children through legal imposition (Ross, 2008). Filial care, once considered a moral duty, has now transformed into a legal obligation due to the reorientation of socio-cultural and economic realities. Although debates persist regarding the rationale and efficacy of such acts in the contemporary modern and neoliberal context, they appear necessary to some extent to contain government spending on long-term elderly care and to redefine the relational aspects of families based on the changing ethos and values of modern society (Bu, 2021; Rozario and Hong, 2011).

The filial responsibility or elderly care act is not a new phenomenon, but the adoption of such an act in Eastern countries represents a relatively recent development. Countries like China, Singapore, and Taiwan, as well as South Asia nations such as India, Sri Lanka, and Bangladesh, have enacted elderly care acts. Although the provisions and mechanisms differ across contexts, the basic premise of these acts is to ensure that elderly parents and family members receive adequate care from their children and relatives to maintain a decent quality of life (Abalos et al., 2018; Ting and Woo, 2009). This provides an opportunity to compare and learn from the experiences of different countries and to delineate what works best to support the elderly. Geva-May (2002) suggests that there will always be a need to draw lessons for governments and public institutions to meet the challenges of emerging global phenomena. However, contextual differences can diminish the opportunities for lesson drawing, even amongst similar policies. Therefore, lesson drawing is most efficient in similar contexts that share similarities but also exhibit some policy variation (Radin and Weimer, 2018).

Against this backdrop, this paper compares and examines how elderly care acts in three jurisdictions — India, Sri Lanka, and Bangladesh — with similar socio-cultural, historical, political, and ethical frameworks. These acts legally frame and transfer the maintenance responsibility of elderly and parental care to the children and family members, enforcing related obligations. Data from UNESCAP (2023) indicates that by 2050, India, Sri Lanka, and Bangladesh will have 20.8 percent, 27 percent, and 21.3 percent of their populations in the ageing group, respectively, who will require diverse support and care. These countries have traditionally relied on family values and structures as the primary institutions for providing care to the elderly. However, they are now facing similar challenges in delivering support to the elderly due to changes in cultural, demographic, and economic realms, making them ideal for comparison. The intention is to draw lessons by comparing the key contents of the acts through qualitative content analysis. This study also provides an opportunity to explore and experiment with different policy instruments to enforce the acts effectively. As Fontaine (2017) suggests, comparative public policy offers benchmarking criteria to understand and initiate policy change, diffusion, and convergence. Therefore, the intention and opportunity presented in this study render it both descriptive and exploratory.

The study aims to compare the differences and similarities between the acts and draw lessons for Bangladesh. Given that Bangladesh’s Parents Maintenance Act still awaits detailed regulations, the findings can serve as an “aider” to address the limitations of the Act in providing benefits to many elders in Bangladesh, making the study a timely effort. For conceptual guidance, this study relies on the literature on policy learning.

This paper proceeds with a discussion of the global landscape of elderly care acts, followed by a brief overview of how this study conceptualizes policy learning and the methods employed for conducting the comparative analysis through qualitative content analysis. Subsequent sections illustrate the significant features of these three acts and present a comparative analysis. Finally, lessons for Bangladesh are drawn from the analysis, followed by the conclusion.

Filial care has roots in ancient history and major religious scriptures such as Christianity, Islam, Hinduism, and Buddhism (Tanggok, 2017). In many countries, particularly in Eastern countries, filial piety is deeply ingrained in the social and cultural heritage. However, cultural and religious teaching weakens over time, and the understanding fades. Consequently, filial piety has evolved into filial care acts. Such acts create a statutory duty for adult children to financially support their parents who are unable to provide for themselves (Pakula, 2005 in Ross, 2008, p. 168). Although these acts have gained attention from policymakers and researchers due to the increasing concern for elderly care and rights, filial care is not a new phenomenon. In fact, the Elizabethan Poor Relief Act of 1601 in England is the earliest known filial care act, imposing the responsibility of caring for indigent parents on their children (Moskowitz, 2001; Pearson, 2013). Since the 19^th century, similar statues have existed in many US states (Pearson, 2013; Rickles-Jordan, 2007). Currently, 28 states have filial laws that serve as mechanisms to commence civil legal proceedings against children who fail to support their parents. In Kentucky, Massachusetts, North Carolina, and Ohio, violations of the law only incur criminal liability on children (Brown, 2020). However, in the US, the maintenance claims by the parents take into account issues such as the children’s past treatment, abandonment, negligence, and the nature of parental support. Additionally, the courts consider the children’s income and their ability to maintain their immediate families. Similarly, all provinces in Canada have filial responsibility laws based on mutuality, under which maintenance claims are decided upon the care and support the children received from parents as minors and the financial ability of both parties (Brown, 2020; Pearson, 2013; Ross, 2008; Ting and Woo, 2009).

On the other hand, countries such as Poland and Ukraine have enforced the family welfare code, which obligates children to support their parents and grants power to courts to enforce this law (Rickles-Jordan, 2007). The Ukrainian legislation allows the court to set alimony as a fixed amount or a percentage of the payer's income, considering both parties' financial circumstances and positions. Furthermore, the Ukrainian family code revokes inheritance rights to children who fail to support their parents. Similarly, Spain and Italy impose civil obligations on children and family members, including half-siblings, to care for the elderly or pay for the expenses. Whereas laws in Slovenia and Portugal extend care obligations to stepparents, aunts, uncles, and parents (Sundström et al., 2008).

In Eastern regions, China and Singapore enacted filial care acts in 1996 and 1995, respectively (Chan, 2004; Chou, 2011). These acts detail the responsibilities of the children in maintaining their parents. The Protection of the Rights and Interests of Aged Act of China entrusts the maintenance responsibility (monetary and non-monetary) not only from children but also from younger to elder siblings, and requires regular visits (Bu, 2021). It also revokes the inheritance rights of children or family members who refuse to perform the duty (Chou, 2011).

The Maintenance of Parents Act of Singapore makes a child, including an illegitimate, adopted, or stepchild, liable to maintain his/her parents. It established a Tribunal to deal with maintenance claims, allowed approved organizations to make claims on behalf of parents, and thus kept such sensitive issues outside the existing judicial system (Chan, 2004; Rozario and Hong, 2011). In Taiwan, filial responsibility law has both civil and criminal liabilities, but the amendment to the law in 2010 has made the previously absolute filial obligations conditional, which include relief or exemption clauses for children who were abused or neglected by their parents (Chang, 2020).

Although doubt and debates prevail on the rationale of the enactment of such laws and their effectiveness in ensuring support for the elderly (Brown, 2020; Chowdhury and Tasnima, 2022; Harkness, 2023; Lyons, 2011; Ting and Woo, 2009), evidence shows that with proper mechanisms and support an increasing number parents in countries such as Singapore, Taiwan and China are suing their children for maintenance (Rozario and Hong, 2011; Shyue-Ren, 2019 in Chang, 2020; Chou, 2011).

From the review of the academic literature on filial and elderly care jurisdictions, three core features become evident: defining maintenance receiver and provider (inclusiveness), the process for claiming maintenance (mechanisms), and the legal consequence of the claims (realization of decisions). These features provide a base for policymakers and researchers to explore what works best. These three categories, named ‘inclusiveness’, ‘mechanisms’, and ‘realization of decisions’, thus work as the primary code for the qualitative content analysis.

It is noteworthy here that learning from different countries allows domestic policy actors to adopt and employ more effective policy designs and instruments in the best interest of the elderly in today’s turbulent world. As mentioned, with the enactment of elderly care acts in India, Sri Lanka, and Bangladesh, South Asia is the latest addition to this elderly care landscape, and therefore, a detailed analysis of the provisions is timely and required to understand whether these acts are effectively designed to fulfil the goals of elderly care provision and protection. However, this study only intends to compare the acts of the three South Asian countries rather than exploring the context and rationale behind their enactment.

This study conceptualizes policy learning, relying on the work of Bennett and Howlett (1992), emphasizing Rose’s (1991) notion of lesson drawing. Through the reconciliation of different approaches to learning in public policy literature, Bennett and Howlett (1992) identified three types of policy learning, including government learning (Etheredge, 1981), social learning (Hall, 1993), and lesson drawing (Rose, 1991), and examined them through three questions. These questions address — who learns, what they learn, and what the effect of that learning is — on a specific policy.

Specifically, government learning refers to learning that occurs within government organizations where state officials enhance their intelligence, sophistication, and effectiveness in policy making through the accumulation and application of knowledge, resulting in organizational change in the form of enhanced efficiency and effectiveness of government operations and processes (Etheredge, 1981; Saner and Yiu, 1996; Yiu and Saner, 1998). In addition, social learning arises from the need to solve complex policy problems where policy communities (a broad group of state and societal actors) learn about the existing framework or belief system that shapes how they understand, interpret, and address specific issues (Hall, 1993; Saner and Yiu, 2018).

Furthermore, in lesson drawing policy networks (actors connected through their roles in policy formulation and implementation) learn from the experience of one jurisdiction to address a similar problem in another through changes in policy instruments, leading to program or policy change (Moyson et al., 2017). Rose (1991) has identified four mechanisms of lesson drawing, including copying (copying policy instruments occurs when social, political, and cultural dimensions in two jurisdictions are identical), emulating (when a program in one jurisdiction is used as a model in another with required alterations in policy instruments), hybridizing (when the instruments of two distinct programs are combined into a new one), synthesizing (when instruments of various programs are synthesized into one).

This study conceptualizes policy learning as lesson drawing through emulating and synthesizing by the policy network that initiates policy change in the case of Bangladesh. Therefore, the analysis of elderly care acts in two jurisdictions to draw lessons can inform improvements to the Parents Maintenance Act 2013 of Bangladesh by suggesting what is to be learned and leading to subsequent options for policy change. To clarify, despite similar contexts of the countries, the lesson drawing is conceptualized as ‘emulating’ and not ‘copying’ in this study to account for Bangladesh’s specific context in the lesson drawing and avoid producing a ‘replica of the ideal’ (Freeman, 2008).

Moreover, learning through emulating and synthesizing and subsequent policy change discussed in this study remains at the meso level that deals with policy tools without delving into micro-level operational details of policy implementation. While policy learning and change often emerge from the interaction of the meso and micro levels (Howlett et al., 2024), the absence of detailed regulation for the Parents Maintenance Act and its non-enforcement status have limited this study to the meso level only through the analysis of policy contents and not focus on the ground specifications of the micro level.

This study employs qualitative content analysis on existing filial and elderly care acts in India, Sri Lanka, and Bangladesh. Drisko and Maschi (2016) state that qualitative content analysis for descriptive research facilitates comparison and evaluation while exploring new avenues for examining an event, which this study aims to achieve. Therefore, qualitative content analysis is appropriate for this study.

This study begins content analysis with three deductively predefined main categories or codes: ‘inclusiveness’, ‘mechanisms’, and ‘realization of decisions’ from the literature review. Additional codes such as ‘time frame’ and ‘role of the state’ were identified inductively during data exploration. Although comparative and evaluative studies usually start with deductive coding, there is flexibility for including codes that may appear in the text through inductive coding (Drisko and Maschi, 2016; Elo and Kyngäs, 2008). Therefore, the combination of the inductive and deductive coding approaches ensures the robustness of the analysis and provides five major provisions of the act that also work as the dimension of learning. Moreover, sub-categories have been created within the main categories to offer a detailed explanation of the categories (Figure 1).

The content analysis is presented in a narrative form in the findings section, which identifies a set of lessons for Bangladesh through emulation and synthesis of the acts from India and Sri Lanka across five dimensions. The adoption of these lessons will hopefully transform Bangladesh’s act into a more comprehensive and detailed framework.

The essential features of these acts that emerged from the content analysis and how they were coded are summarized in Table 1.

This section presents the findings from content analysis by highlighting the similarities and differences among the three acts.

Under India’s act, parents (including biological, adoptive, and step), grandparents, and senior citizens, have the right to seek maintenance from their children, grandchildren, and specified relatives (Ministry of Law and Justice, 2007, ss. 2(d), 4(1)). The Act explicitly states that senior citizens who are 60 years old or older, as well as parents who are unable to support themselves, regardless of their age, are entitled to claim maintenance from their children (Ministry of Law and Justice, 2007, ss. 2(h), 4(1)). While the act of Sri Lanka states that only biological, foster, and stepparents are entitled to seek maintenance if elders cannot maintain themselves and are over 60 years old (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, ss. 25(1), 44), this provision also applies to parents who are younger and have physical and mental infirmity (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 25(4)). Whereas the act of Bangladesh, without addressing age limit, mental or physical disability, or parents' financial capabilities, restricted entitlement to maintenance only to biological parents and, in the absence of parents, to only grandparents (Ministry of Social Welfare, 2013, ss. 2, 4). It also does not include step or adopted parents despite their contribution to raising the children. The provision of maintenance in all these acts covers food, clothing, residence, medical treatment, and companionship (Ministry of Law and Justice, 2007, s. 2(b); Ministry of Social Welfare, 2013, s. 2(b); Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 25(3)).

Children and specified relatives are obliged to provide sufficient means to provide maintenance for their biological, adoptive, and stepparents, grandparents, and childless senior citizens under the Indian Act (Ministry of Law and Justice, 2007, ss. 2(a), 2(d), 4 (2-4)). While in Sri Lanka, children, including step, adopted or illegitimate, are required to provide maintenance to parents (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, ss. 25(1), 44). Conversely, the Act of Bangladesh only held biological children and grandchildren responsible for providing maintenance. It specified that children must regularly contribute a reasonable portion of their income to parents if they do not reside with them (Ministry of Social Welfare, 2013, s. 2, 4, 3(7)). However, the Act does not confer any responsibility to adopted or stepchildren.

Under India’s act, the state government must constitute separate Maintenance and Appellate Tribunals in each subdivision within six months (Ministry of Law and Justice, 2007, ss. 7(1), 15(1)). Several maintenance boards equivalent to district courts are established in Sri Lanka to deal with maintenance claims (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, ss. 24 (1-2)). However, complaints are to be filed in the Court of Magistrate or the Metropolitan Court in Bangladesh (Ministry of Social Welfare, 2013, s. 7). Accordingly, the acts of India and Sri Lanka envisaged the effect of such claims on family relations and reputation, thereby constituting a separate legal institution to deal with such a sensitive issue. For instance, the Boards in Sri Lanka can appoint a conciliation officer with the consent of the concerned parties to negotiate between them (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 27(6)). Moreover, India restricts lawyer involvement in such cases, instead only allowing parents and senior citizens to avail the services of a maintenance officer to deal with the maintenance claims (Ministry of Law and Justice, 2007, ss. 17-18). Similarly, Sri Lanka’s Act prohibits any public inquiry regarding the maintenance claim (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 24(1); Parliament of the Democratic Socialist Republic of Sri Lanka, 2011, ss. 8, 9).

The act of Bangladesh allows the parents to file complaints in the magistrate court and empowers the court to refer the complaint to the concerned representatives of the local government institutions or any competent person to resolve the complaints through compromise (Ministry of Social Welfare, 2013, s. 8). But no separate tribunal or court has been constituted exclusively to deal with these maintenance claims nor any provision for conciliation or maintenance officer. It also does not restrict the appointment of a legal practitioner or public inquiry in the proceedings of maintenance claims, which can exacerbate financial burden (Ministry of Social Welfare, 2013, s. 7(1)). Therefore, the Act failed to comprehend the sensitivity of the issue and the complexity of legal proceedings, which can strain parent-child relations and, in some cases, cause social humiliation. Thus, many elders may endure in silence due to ingrained cultural, religious, and family values, and those who seek legal recourse may face additional hassles due to the extensive judicial backlog in Bangladesh (Tahura, 2022).

In the cases of India and Sri Lanka, maintenance claims can be initiated against any child or relative in any district where the parent or senior citizen lives or last lived or where the child or relative lives (Ministry of Law and Justice, 2007, s. 6(1); Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 32). Both acts allow making an application by any other authorized person, registered voluntary organization, or any other means if the parents cannot make an application (Ministry of Law and Justice, 2007, s. 5(1); Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 25(2)). Unlike India and Sri Lanka, there is no provision for any person or organization to file a complaint on behalf of parents in Bangladesh. Instead, only parents themselves can complain or file a case against the children (Ministry of Social Welfare, 2013, s. 7(2)). The act has failed to consider the plight of many uneducated elderly people with physical and mental infirmity, who are unaware of the act or too shy or stigmatized to complain against their children.

In India, the tribunal can arrange for month-to-month recompense as it deems fit to be paid to the parents. Children or relatives must deposit the entire amount within 30 days of the date of the order, and the maximum amount of maintenance must not exceed 10,000 rupees per month (Ministry of Law and Justice, 2007, s. 9(1-2), 13). Nevertheless, comparing this amount with the poverty line in India, which is 1,929 and 1,622 rupees for urban and rural areas, respectively, raises concern about the rationale of this cap (Forbes India, 2024). The tribunal may also issue interim orders for maintenance and include an additional simple interest on the maintenance amount, ranging from 5 percent to 18 percent, to accrue from the date the initial maintenance request was filed (Ministry of Law and Justice, 2007, ss. 5(2), 14).

In Sri Lanka, the Board can order monthly lump sum, or periodic allowances to be paid to parents, order deposits of the minimum sum in the bank, or purchase an annuity if the parties fail to mediate the differences (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, ss. 28 (1-2); Parliament of the Democratic Socialist Republic of Sri Lanka, 2011, s. 10). Furthermore, the act empowered the Board to request the employer of the children to deduct the same amount from the salary and remit it to the parents (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 32). However, the Board can reduce the “quantum of maintenance” orders, the discretionary amount to be paid by either party as Maintenance determined by the Court, if there is proof of prior child abandonment or abuse by parents (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, ss. 27 (3-4)). In Bangladesh, the act lacks clear guidance for deciding the monthly maintenance amount to be paid to parents nor the process of collecting the maintenance amount from the children. As a result, there remains ambiguity as to the determination of the amount for maintenance and possibly deserving parents stranded.

According to the Indian Act, children and relatives will face one-month imprisonment in case of failure to provide the maintenance amount as decided by the tribunal and may extend such imprisonment until the payment is cleared (Ministry of Law and Justice, 2007, s. 5(8)). It also allows the elderly to reclaim property from their children and relatives if they fail to provide certain amenities and maintenance as promised (Ministry of Law and Justice, 2007, s. 23(1)). It also specifies that for abandonment of parents and senior citizens, children or relatives will be subject to imprisonment for no less than three months and a fine which may extend to 5,000 rupees or both (Ministry of Law and Justice, 2007, s. 24). Similarly, in Sri Lanka, a Magistrate having jurisdiction over the place where the complaint is made can enforce the maintenance order under the maintenance ordinance (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 32). In case of failure to comply with the maintenance order, children will be liable to a fine of 100,000 rupees or imprisonment for a term not exceeding one year, or both (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 41(e)).

In Bangladesh, the Act has the provision of Tk. 100,000 as a fine and, in default, three months in jail for failure to provide maintenance to the parents or to force them to live at an old age home or any other place against their will (Ministry of Social Welfare, 2013, ss. 3, 5). Spouses or any relative, including the children's in-laws, who object to providing support to parents will also be liable for punishment. Both Sri Lanka’s and Bangladesh’s acts, however, remain silent about the abandonment of parents and only focus on maintenance or financial penalties. Unlike India, Sri Lanka’s and Bangladesh’s acts do not entitle the elderly to claim their property back from children in case of negligence and abandonment, nor do they have any provision against elder abuse.

According to the act in India, the complaint must be dealt with within 90 days (Ministry of Law and Justice, 2007, s. 5(4)). Although there is no specific timeframe to resolve the complaint in Sri Lanka, any dissatisfied party can appeal within 21 days from the date of the Board’s decision (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 24(2)). However, the Parents Maintenance Act of Bangladesh does not mention any time limit for settling complaints or appealing against the court's decision.

India’s act directs the state to constitute Maintenance and Appellate tribunals, designate Maintenance Officers, establish and maintain homes for indigent elders, and raise awareness (Ministry of Law and Justice, 2007, ss. 7(1), 15(1), 18(1), 19(1-2), 21). Similarly, Sri Lanka’s act assigns the state to establish a National Council and Secretariat for elders, constitute maintenance board(s), provide residential facilities for destitute elders, register persons and voluntary organizations to support elders, and establishment of a fund for the elder welfare (Parliament of the Democratic Socialist Republic of Sri Lanka, 2000, s. 15(2), 24, 25(2)). However, although Bangladesh’s act empowers the state to frame rules to fulfil the objectives of the act, it does not detail any support mechanism or impose any binding obligations on the state to support abandoned, destitute, and childless parents/elderly who have no option for maintenance or daily living.

The findings revealed that, although not perfect, both India’s and Sri Lanka’s acts outline detailed scopes of responsibility and maintenance entitlement, as well as flexible and precise complaint and decision mechanisms, along with a clear delineation of responsibilities for the states. Such details are absent in Bangladesh’s act, and the existing provisions have not been tailored to the contextual realities of the country. Therefore, the comparative analysis enables Bangladesh to understand how to design a more inclusive and comprehensive policy in a similar context by ‘emulating’ and ‘synthesizing’ these elements at the meso level, ultimately leading to the development of new legal instruments and subsequent policy change. Moreover, the prevalence of financial, physical, and psychological elder abuse among all social classes in Bangladesh necessitates this learning and rectification of the act (Farid, 2017). Based on the analysis, Table 2 presents some specific policy learnings for Bangladesh. It suggests what can be learned to improve the existing policy instruments and amend the Parents Maintenance Act, 2013, as well as the benefit such policy changes can offer to the elderly across these five dimensions of inclusiveness, mechanisms, realization of decision, time frame, and role of the state.

The lessons drawn for Bangladesh can be considered for inclusion in the framing of new rules and regulations for the Parents Maintenance Act, 2013 of Bangladesh, which still awaits to come into effect.

Along with drawing the lessons for Bangladesh, this study contributes by filling the gap in comparative elderly care literature in South Asia and suggesting learning for the policy network. Specifically, by analyzing the comparative gaps of the Parents Maintenance Act, the study identifies what lessons policymakers in Bangladesh can draw from India and Sri Lanka, mainly from a legal text point of view, leading to the potential strengthening of existing instruments and policies. This learning can also serve as useful knowledge for other South Asian countries to enact elderly care acts in future. Moreover, the study offers further scope for empirical public policy scholarship on policy learning and elderly care.

Since the study is conducted on the descriptive content analysis of the acts, it primarily compared and identified the limitations of Bangladesh’s act to draw lessons guided by policy learning concepts. Therefore, empirical research with comparative data is suggested to further develop the understanding of the efficacy of the suggested learning. In addition, future studies could compare the implementation practices, challenges, and impacts of the legislation concerning the welfare of destitute elderly. Furthermore, gathering views and experiences from policymakers, implementers, advocates for elder issues, and target groups regarding such acts would enhance the learning of policy networks. This comparative analysis also contributes to better law-making aimed at protecting the elderly, especially in developing countries where social protection systems remain deficient. Finally, since this study focused solely on the South Asian region, future research on cross-regional comparisons is encouraged to address a broader range of global experiences in this policy domain.

This study compared the elderly care acts in India, Sri Lanka, and Bangladesh. It highlighted differences among the acts in terms of inclusiveness, mechanisms, realization of decisions, time frame, and the role of the state in the implementation of these acts. It was found that although Bangladesh modelled the act after those of India and Sri Lanka, it lacks pragmatic views to ensure the care and rights of the elderly. The act’s inclusivity is limited by the absence of clear guidance and mechanisms for making claims and conferring maintenance decisions. Both could increase judicial gridlock. Additionally, the act portrays less administrative and legal sensitivity and consensus regarding the balance between elder care responsibilities and the protection of family reputation and harmony. Furthermore, the act neglects the issue of elder abuse and reveals lower awareness about it. To improve policy design and implementation, the study suggested specific lessons from the Indian and Sri Lankan acts that could better support elders. These include expanding the definition of parents to include the term “senior citizens”, establishing an independent commission or separate tribunal with the sole responsibility for dealing with maintenance claims, creating a dedicated administrative agency to support destitute elders, and organizing elder committees at various levels with the involvement of registered voluntary organizations. Considering the ageing trend and elder care challenges in Bangladesh, such lessons can be applied for more pragmatic and progressive policy design.