Karaite Judaism relies on the Tanakh to indicate that Jewishness is passed down through the paternal line, not the maternal line as is maintained by Orthodox Judaism (though a minority holds that both parents need to be Jewish). Karaite Jews are eligible for Aliyah under the Law of Return. The eligibility of converts to Judaism through the Karaite movement to make Aliyah under the Law of Return has not yet been addressed in Israeli courts. Several verses in the Bible mentioning about laws of family inheritance depending on the paternal lineage of the tribe: Reform Judaism Reform Judaism recognizes a child as being Jewish if either parent is Jewish and the child is being raised Jewish. Voices within the Reform movement say that the law, which changed to matriarchal around 2,000 years ago (originally in the Torah the offspring was determined by patriarchal descent) and was based on the tragic circumstances the Jewish people were facing, was once helpful but is no longer relevant. Modern Progressive Jewish denominations have a conversion process based on their principles. In the US, an official Reform resolution in 1893 abolished circumcision as a requirement for converts, and Reform does not require converts to have tevilah, ritual immersion. A "prospective convert declares, orally and in writing, in the presence of a rabbi and no less than two lay leaders of the congregation and community, acceptance of the Jewish religion and the intention to live in accordance with its mitzvot". Controversies The controversy in determining "who is a Jew" concerns four basic issues: One issue arises because North American Reform and UK Liberal movements have changed some of the halakhic requirements for Jewish identity in two ways: Secondly, Orthodox Judaism asserts that non-Orthodox rabbis are not qualified to form a beit din. This has led to non-Orthodox conversions generally being unaccepted in Orthodox communities. Since Orthodox Judaism maintains the traditional standards for conversion – in which the commitment to observe halakha is required – non-Orthodox conversions are generally not accepted in Orthodox communities because the non-Orthodox movements perform conversions in which the new convert does not undertake to observe halakha as understood by Orthodox Judaism. A third controversy concerns persons (whether born Jews or converts to Judaism) who have converted to another religion. The traditional view is such persons remain Jewish. Reform Judaism regards such people as apostates, and states regarding Messianic Jews: Messianic Jews' claim