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How States Apply It Today, and How Unevenly

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How States Apply It Today, and How Unevenly

No two Muslim-majority states apply "sharia" the same way, and the range illustrates the point about codification made elsewhere in this collection: each is a modern state choosing what to enact, not a single system being uniformly followed.

Most Muslim-majority countries, including Egypt, Jordan, Tunisia and Turkey, apply sharia-derived rules narrowly, chiefly to family law, marriage, divorce and inheritance, while running civil and criminal codes substantially based on European models inherited from the colonial or Ottoman period. Turkey abolished sharia courts entirely under Ataturk's reforms in the 1920s. Tunisia's 1956 Code of Personal Status went further than most, banning polygamy outright, a position defended as consistent with a purposive reading of the Quranic conditions for plural marriage rather than as a rejection of Islamic law.

A smaller number of states apply criminal hudud penalties in some form. Saudi Arabia and Iran apply them as part of a broader claimed sharia framework, though Iran's system is filtered through its own codified penal law and Twelver jurisprudence rather than the Sunni schools. Several northern Nigerian states adopted hudud provisions after 1999, alongside a federal secular system that continues to operate in the same country. Aceh, a special autonomous province of otherwise secular Indonesia, applies sharia-based bylaws including caning for some offences, a specifically local arrangement not found elsewhere in the country.

Malaysia and several Gulf states run dual systems, separate sharia courts for Muslim family matters alongside secular civil courts for everyone else, an arrangement that generates disputes when the two systems' jurisdictions intersect, notably in conversion and custody cases.

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