Analisis Perundangan Penjagaan Warga Emas di United Kingdom, Australia dan Jepun.

The modern guardianship system is derived from the common law. This guardianship system prioritises the doctrine of parens patriae which means that the courts are allowed to intervene to take care of the interests of those who are unable to care for themselves, such as children and adults through the appointment of guardians. Although Malaysia still does not have specific laws for elderly guardianship, various developments and advances in laws related to the elderly guardianship have taken place in other countries. In line with that, this paper will analyse the legal framework with regards to elderly guardianship system in three selected countries, namely the United Kingdom, Australia and Japan. These three countries were chosen on the grounds of their long histories and well-established system at present. Apart from that, legal reforms have always been carried out to safeguard this group. To achieve the objectives outlined qualitative approach of content analysis. It was discovered that although guardianship laws in the United Kingdom, Australia and Japan do not specifically aimed at the elderly, the legal mechanisms that exist in all these jurisdictions have benefited the elderly. The elderlies who are without mental capacity to manage themselves and property, are protected by laws that can be considered comprehensive and robust in all three jurisdictions. This is evidenced by the application of adults guardianship system’s statistic for the elderly. The elderly are included in the category of adults with incapacity and they are the largest group under these guardianship laws. Therefore, it is recommended that relevant authorities should take the effort in integrating the different approaches applied in these three jurisdictions to come out with a comprehensive legal mechanism for elderly guardianship in Malaysia. [ABSTRACT FROM AUTHOR]