In Shavdarov v Bulgaria, the Court noted that the applicant had lived with the children as their father for a number of years and concluded that family life existed.
The Convention does not guarantee the right to adopt as such and Article 8 does not oblige states to grant a person the status of adoptive parent or adopted child. (nota de subsol 450: X v Belgium and Netherlands, 6482/74 + Di Lazzaro v Italy, 1997)
D. J. Harris, M. O’Boyle, E. P. Bates, C. M. Buckley
(Law of the European Convention on Human Rights, Oxford University Press, august 2018, la p. 543 și 545)