In re A.J.A.

The issue in this case is whether the case was tried under Code § 74-405 (a) or (b) (of the same code section). If under the latter, the adopting parents must meet the requirements set forth in Code § 74-403 (a) (3) or (4) as a spouse of the other parent, or a parent, brother or sister, aunt or uncle, son or daughter of either parent. One of the petitioners here is a first cousin of the biological mother.

1. As to Code § 74-405 (a). The Supreme Court case of Glendinning v. McComas, 188 Ga. 345 (3 SE2d 562) (1939) has made clear the rigid requirements in abandonment cases and the burden of…