Authorization for an Adopted Adult to Resume their Original Surname

Facts

This case concerns Ralph Léon Lévy, who was adopted as an adult by his stepfather Roger Albert Perrenoud. As a result of this adoption, Ralph Léon Lévy lost his original surname, Lévy, and took the surname Perrenoud. In 1980, Ralph Léon Perrenoud requested authorization from the State Council of the Canton of Geneva to change his name back to Lévy, which was denied. He then appealed to the Federal Tribunal.

Considerations

The Federal Tribunal upheld the appeal. It considered that, although adoption normally results in the change of the adopted person's surname, they may nevertheless be authorized to resume their original surname if they have valid reasons to do so under Art. 30 para. 1 CC.

In this case, the Federal Tribunal found that the fact that Ralph Léon Perrenoud is of Jewish faith and that the name Lévy has a particular significance in Jewish tradition and culture constituted a valid reason justifying the authorization to change his name. The Tribunal considered that the loss of…