CONFLICT OF LAWS IN INTERNATIONAL MUSLIM MARRIAGES: LEGAL CHALLENGES AND HARMONIZATION APPROACHES ACROSS JURISDICTIONS

As globalization increases the rates of international Muslim marriages, varied interpretations of Islamic marriage law across jurisdictions present multifaceted legal challenges.​ Several conflicts flow in the issues of marital rights, procedures of divorce, and inheritance rights that spring from the differences in legal traditions and socio-cultural contexts. In Muslim-majority countries, the reconciling of interpretations of Sharia to secular legal frameworks creates sometimes difficult scenarios on practices that include unilateral divorce (talaq) and polygamy. These disparities lead to complications on the consent issue, dowry or mahr, and recognizing marriages across borders.