They could have adopted him after the adoption law came in, but yes, I think you're right that the records would be closed. But as I understand it, you can search the Adopted Children's Index to see if he is listed on there, and the GRO website says that "The public indexes to these records are available at Birmingham Central Library, Bridgend Reference and Information Library, The British Library, City of Westminster Archives Centre, London Metropolitan Archives, Greater Manchester County Record Office and Plymouth Central Library."
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