Abstract
Marriage (Nikah) in Islamic law is conceived not merely as a lawful avenue for intimacy but as a moral covenant oriented toward tranquility (sukūn), affection (mawaddah), mercy (raḥmah), and social stability. Yet contemporary Muslim societies increasingly encounter alternative marital forms, most notably Mutʿah (temporary marriage) and Misyar (a reduced-rights permanent marriage) that depart from the traditional model of family-building.
This article offers a comprehensive doctrinal and ethical analysis of these two forms through a comparative Sunni-Shiʿi framework. It traces the Qur’anic and Prophetic foundations invoked in their justification or prohibition, maps the divergence between Sunni and Twelver Shiaʿi jurisprudence on Mutʿah, and examines the modern Sunni validation of Misyar based on procedural compliance with the pillars of Nikah.
Moving beyond formal legality, the article evaluates both practices through the lens of maqāṣid al-sharīʿah (objectives of Islamic law), with particular emphasis on dignity, lineage, welfare, and social order. It argues that while Mutʿah remains doctrinally lawful within Shiaʿi jurisprudence and prohibited within Sunni law, and while Misyar is often treated as formally valid in Sunni Fiqh, both risk ethical erosion when instrumentalised as mechanisms of convenience, secrecy, or “halal dating.”
The article concludes that the legitimacy of marriage in Islam cannot rest on contractual form alone. Where commitment, accountability, and protection of the vulnerable are absent, the moral architecture of Nikah collapses. It proposes regulatory and ethical safeguards, mandatory registration, informed consent, non-secrecy, non-waivable child protections, and anti-exploitation norms, to reconcile doctrinal diversity with the Qur’anic vision of marriage as a covenant of responsibility rather than a vehicle of expedience.
Keywords:
Islamic Family Law; Nikāḥ; Mutʿah; Temporary Marriage; Misyar Marriage; Sunni Jurisprudence; Shiaʿi Jurisprudence; Maqāṣid al-Sharīʿah; Gender Justice; Marriage Ethics; Muslim Personal Law; Contemporary Fiqh; Halal Dating; Family Regulation
Executive Summary
This article undertakes a comparative and normative examination of Mutʿah (temporary marriage) and Misyar (a reduced-rights, typically non-cohabiting marriage) as two contemporary and contested forms of Nikah. It situates these arrangements within their doctrinal foundations, analyses their operation in lived practice, and evaluates the extent to which Muslim legal systems regulate or fail to regulate, their consequences.
At the doctrinal level, the divergence over Mutʿah is foundational rather than cosmetic. Twelver Shīʿī jurisprudence commonly anchors Mutʿah in Qur’ān 4:24, interpreting the verse as authorising a distinct contractual form of marriage characterised by a specified term and dower. Sunni doctrine, by contrast, treats Mutʿah as abrogated and prohibited on the basis of Prophetic reports preserved in the principal Sunni hadith collections, including Ṣaḥīḥ al-Bukhari and Ṣaḥīḥ Muslim. This has produced a near-consensus of prohibition within Sunni Fiqh. The disagreement, therefore, is not marginal but rooted in competing hermeneutics of text, authority, and abrogation.
Misyar presents a different juristic problem. In Sunni law it is not conceived as “another kind of Nikah,” but rather as an ordinary marriage in which certain post-contractual rights, such as maintenance, cohabitation, or equal overnight division, are waived by consent. Many Sunni jurists accept its formal validity on the ground that the arkān and shurūṭ of marriage are satisfied, even as they caution against its social consequences. Egypt’s Dār al-Iftā’ has explicitly framed Misyar as valid where the legal integrals and conditions of marriage are fulfilled, thereby reinforcing the distinction between contractual validity and ethical desirability.
The most acute contemporary problem, however, lies not in form but in function. Both Mutʿah and Misyar are vulnerable to instrumentalisation, including through “halal dating” narratives, secrecy, and structural power imbalances. These dynamics disproportionately impair women’s enforceable rights and jeopardise children’s welfare, particularly in contexts where registration and documentation are weak or absent.
Comparative analysis demonstrates that national regulation is the decisive variable in determining harm. Where states mandate registration and provide accessible, enforceable family-law remedies, abuses are more readily contained. Where marriages remain informal or concealed, women and children experience markedly higher legal vulnerability.
The policy implication is clear. Even where a contract may be juristically arguable, public policy must insist upon minimum safeguards: mandatory registration, informed consent, non-secrecy, enforceable maintenance and child-support obligations, and robust anti-exploitation rules. Only through such measures can doctrinal diversity be reconciled with the Qur’anic vision of marriage as a covenant of responsibility rather than a vehicle of convenience.
1. Introduction: Marriage as Covenant, Not Mere Permission
The Qur’an frames marriage as a sign (āyah) tied to sukūn (tranquility), mawaddah (affection), and raḥmah (mercy).¹ This normative ideal is paired in juristic literature with duties of maintenance, companionship, lineage protection, and public acknowledgement of marriage-so that Nikah functions as a stabilising social institution, not merely a licit gateway to intimacy.²
Contemporary debates around Misyar and Mutʿah pivot on a central tension: formal legality versus substantive objectives. Even where a contract meets procedural requirements, critics argue it may subvert the purposes of Nikah if it becomes a mechanism to minimise responsibility or conceal relationships in ways that undermine women’s security and children’s rights.³
2. Method and Scope
This study employs doctrinal analysis (Qur’an and authenticated hadith), comparative Fiqh mapping (Sunni and Shiʿi positions), and a normative evaluation grounded in maqāṣid al-sharīʿah, contemporary fatwa literature, and academic scholarship.⁴
3. Mutʿah (Temporary Marriage): Text, History, and Jurisprudence
3.1 Definition
Mutʿah is a contract specifying a fixed term and an agreed dower/compensation, after which the union ends automatically without divorce.⁵
3.2 Shiʿi Legal Reasoning
Twelver Shiʿi jurists generally regard Mutʿah as lawful, relying primarily on Qur’an 4:24 as authorising a contractual form of marital enjoyment with compensation.⁶ In Shiaʿi legal theory, Mutʿah is often presented as a regulated alternative to illicit relations where permanent marriage is impracticable.⁷
3.3 Sunni Legal Reasoning: Abrogation and Prohibition
Sunni jurists overwhelmingly regard Mutʿah as prohibited, relying on authenticated Prophetic reports indicating permanent prohibition. A frequently cited narration in Ṣaḥīḥ al-Bukhari links the ban to Khaybar.⁸ Other reports situate the final prohibition around the Conquest of Makkah.⁹ While hadith scholarship debates chronology, the dominant Sunni conclusion remains prohibition.¹⁰
3.4 Contemporary Practice
In modern settings, Mutʿah can function either as a narrowly used juristic option within specific communities or as a commodified practice vulnerable to exploitation, especially where secrecy, short terms, and economic disparity transform marriage into a transactional encounter.¹¹
4. Misyar Marriage: Validity, Waiver of Rights, and Secrecy
4.1 Definition
Misyar is a Sharʿī Nikah in which the parties fulfil the pillars of marriage but the wife voluntarily waives certain practical rights, commonly maintenance or cohabitation.¹²
4.2 Validity and Ethical Appraisal
A major strand of Sunni fatwa reasoning considers Misyar formally valid if the essentials of Nikah are met, even if it is disliked or harmful when misused.¹³ This distinguishes ṣiḥḥah (validity) from ethical and social appraisal (karāhah and mafsadah).¹⁴
4.3 Waiver and Reassertion of Rights
Scholarly treatments note that a wife’s waiver may be revocable; she may later reassert her rights, obliging the husband to comply or dissolve the marriage.¹⁵ This underscores that Misyar remains a marriage contract with baseline obligations.
4.4 Secrecy
The gravest ethical objections arise where Misyar becomes a “hidden marriage,” undermining public acknowledgement and protective functions of nikāḥ.¹⁶
5. Comparative Overview
| Feature | Mutʿah | Misyar |
| Duration | Fixed term | Indefinite/permanent |
| Sunni ruling | Prohibited | Often valid if conditions met |
| Shiʿi ruling | Permissible | Not central as a distinct category |
| Rights | Contractual, time-bound | Standard Nikah; rights may be waived |
| Core concern | Temporality | Reduced responsibility & secrecy |
6. Maqāṣid al-Sharīʿah
The maqāṣid framework asks whether a practice advances the objectives of family law, protection of lineage, dignity, welfare, and social order.¹⁷ Even where procedurally valid, arrangements that defeat sukūn, mawaddah, and raḥmah fail the substantive test.¹⁸
7. Digital Instrumentalisation
Marketing Misyar or Mutʿah as “halal dating” inverts the moral grammar of Nikah, turning marriage into a tool to bypass responsibility. The risks include coercion, uninformed consent, denial of maintenance, reputational harm, and insecurity for children.¹⁹
8. Regulatory Safeguards
- Mandatory registration and documentation.
- Non-secrecy / minimum publicity.
- Informed consent with written rights disclosure.
- Non-waivable minimum protections.
- Automatic, enforceable child support.
- Anti-exploitation enforcement against intermediaries.
9. The Basis of the Shiaʿi Interpretation of Mutʿah
The Twelver Shiaʿi position on Mutʿah (temporary marriage) rests upon a distinctive hermeneutic of Qur’ān 4:24 and a particular reading of early Islamic history. The verse states:
“So for whatever you have benefited from them, give them their due compensation as an obligation.” (Qur’ān 4:24)
Shiaʿi exegetes interpret the phrase mā istamtaʿtum bihi (“whatever you have benefited from”) as a direct textual authorisation of a contractual form of marriage based on time-bound enjoyment in exchange for a specified dower. Classical Shīʿī tafsīr works, such as al-Ṭūsī’s al-Tibyān and al-Ṭabrisī’s Majmaʿ al-Bayān, read this verse as establishing Mutʿah as a lawful institution distinct from permanent Nikah, rather than as a mere reference to ordinary marital relations.
From this perspective, Mutʿah is not an exceptional dispensation but a normative legal category within family law. Shiaʿi jurists argue that the Qur’anic text is explicit and that no unequivocal Qur’anic abrogation exists. Consequently, any claim of prohibition must rely on Prophetic reports. Here, the Shiaʿi methodology diverges sharply from the Sunni approach.
In Twelver Shiaʿi legal theory, reports transmitted through certain Companions, particularly those associated with the Umayyad period, are approached with historical caution. Shiaʿi scholars maintain that while temporary prohibitions may have occurred during specific military campaigns, there is no conclusive proof of a final, permanent abrogation by the Prophet ﷺ. Instead, they attribute the general ban on Mutʿah to the policy of Caliph ʿUmar ibn al-Khaṭṭāb, who famously declared:
“Two Mutʿahs were permitted in the time of the Messenger of Allah, and I forbid them: Mutʿat al-Ḥajj and Mutʿat al-Nisa.”
Shiaʿi jurisprudence treats this declaration not as a continuation of Prophetic command but as an act of ijtihād by a temporal authority, which cannot override an explicit Qur’anic provision. The Imams of the Ahl al-Bayt, particularly Jaʿfar al-Ṣādiq, are reported in Shiaʿi hadith collections to have reaffirmed the permissibility of Mutʿah, framing it as a divine concession and a lawful safeguard against zinā.
Thus, the Shiaʿi position is grounded in three interlinked foundations:
- Textual Literalism of Qur’ān 4:24 – reading istimtāʿ as a juristic category of marriage.
- Rejection of Permanent Abrogation – holding that no Prophetic prohibition conclusively repealed the Qur’anic ruling.
- Authority of the Ahl al-Bayt – privileging the interpretive tradition of the Imams over later political directives.
Within this framework, Mutʿah is conceived not as moral laxity but as a regulated institution with defined conditions-specified term, agreed dower, waiting period (ʿiddah), and lineage attribution-intended to operate within Sharīʿah rather than outside it. Shiaʿi jurists therefore characterise Mutʿah as a legal safety valve in human relationships, particularly in contexts of travel, displacement, or social constraint.
The enduring controversy does not stem merely from textual disagreement but from two competing visions of marriage: one that insists on permanence as an essential attribute, and another that permits temporality as a legitimate juristic form within the Qur’anic economy of relationships.
10. The Juristic Basis of Misyar in Sunni Interpretation
Unlike Mutʿah, Misyar does not arise from a distinct Qur’anic verse or a special prophetic dispensation. Its legitimacy in Sunni jurisprudence is derived from a formalist understanding of Nikah: if the essential pillars (arkān) and conditions (shurūṭ) of marriage are fulfilled, the contract is legally valid, even if the spouses privately agree to modify or waive certain consequential rights.
10.1. Classical Sunni Fiqh defines a valid Nikah through four core elements:
- Ījāb and Qabūl (offer and acceptance),
- Presence of witnesses,
- Specification of mahr (dower), and
- Absence of legal impediments (e.g., prohibited degrees of kinship).
Maintenance (nafaqah), cohabitation, and equitable overnight division in polygyny are treated as effects (āthār) of marriage rather than its conditions. Consequently, a wife may, according to many jurists, voluntarily waive some of these effects without nullifying the contract.
The doctrinal foundation for this reasoning is often traced to an episode involving Sawdah bint Zamʿah (رضي الله عنها), one of the wives of the Prophet ﷺ. As reported in Ṣaḥīḥ al-Bukhari, Sawdah feared divorce in old age and voluntarily relinquished her turn to ʿĀʾishah, and the Prophet ﷺ accepted this arrangement. This precedent is read by contemporary jurists as establishing that:
- marital rights may be voluntarily waived, and
- such waiver does not invalidate the marriage.
On this basis, modern Sunni scholars argue that if a woman knowingly consents to waive maintenance or cohabitation at the time of marriage, the Nikah remains ṣaḥīḥ (valid). Shaykh Yūsuf al-Qaraḍāwī and others have articulated this position: Misyar is legally valid so long as the pillars of Nikah are present, though it may be morally disliked (makrūh) or socially harmful if misused.
10.2. The Sunni justification of Misyar therefore rests on three interconnected premises:
- Formal Validity Principle – Nikāḥ is constituted by offer, acceptance, witnesses, and mahr. Rights such as maintenance are consequences, not preconditions.
- Permissibility of Waiver – A spouse may voluntarily relinquish certain entitlements, as evidenced by prophetic precedent.
- Contractual Freedom within Sharīʿah – Parties may structure their marital life by mutual consent, provided no explicit prohibition is breached.
Within this framework, Misyar is not conceptualised as a new category of marriage but as an ordinary Nikah with atypical internal arrangements. Jurists therefore distinguish between:
- Ṣiḥḥah (legal validity), and
- Ṣalāḥiyyah (moral or social soundness).
A contract may be valid yet undesirable. Many scholars who uphold the formal validity of Misyar simultaneously caution that it can undermine the spirit of marriage if it becomes a mechanism for secrecy, exploitation, or evasion of responsibility. They emphasise that the woman’s waiver must be:
- informed,
- voluntary, and
- revocable.
If the wife later retracts her waiver and demands maintenance or cohabitation, the husband must either fulfil these obligations or dissolve the marriage.
Thus, the Sunni basis for Misyar does not sanctify diminished responsibility; it merely affirms that lawfulness flows from form, while moral worth flows from purpose. The controversy surrounding Misyar arises not from its juristic mechanics but from its modern social function—where a tool meant for exceptional circumstances risks becoming a routinised substitute for full marital commitment.
11. Comparative Study: How Different Muslim Countries Treat Mutʿah, Misyar, and “Informal Marriages”
Below is a comparative mapping (doctrine + state-law practice). Because “Misyar” is often a social practice more than a codified legal category, states typically regulate it indirectly via registration, proof, and family-law remedies.
11.1. Saudi Arabia (Sunni, Hanbali influence; Misyar practice)20
- Misyar: Became widely discussed as a practice; significant fatwa-level acceptance is often associated with senior Saudi scholarship (including references in academic treatments of the 1990s debate).
- Mutʿah: Not accepted in Sunni doctrine.
- Regulatory reality: the key controversy is not “validity on paper” but secrecy, reduced rights, and enforcement (maintenance, disclosure, and child rights), especially if parties keep it informal.
11.2. Egypt (Sunni; strong institutional fatwa landscape)21
- Misyar: Egypt’s Dār al-Iftā’ states it is valid if it meets the integrals/conditions of marriage and there is no legal impediment.
- Mutʿah: Generally treated as prohibited under Sunni doctrine.
- Related phenomenon — ʿUrfi marriage: Egypt has long wrestled with unregistered customary marriages, which create litigation and protection gaps. A UK tribunal decision discussing Egyptian law notes that under Article 17 of Egypt’s Personal Status Law 1/2000, wives in ʿurfi marriages may seek judicial dissolution if the marriage is proven.
Practical takeaway: Egypt demonstrates the problem of “informal marriage”: even if religiously performed, women’s effective rights depend on the state’s approach to proof, registration, and remedies.
11.3. Iran (Twelver Shīʿī; Mutʿah/temporary marriage is legally recognised)22
Mutʿah (temporary marriage): Recognised within Iranian legal and doctrinal framework; contemporary legal literature summarises that Iran’s family law/civil code recognises temporary marriage as a category with defined legal effects.
Practical takeaway: Iran is a prime example where Mutʿah is not merely a doctrinal view but a legally available institution, which affects how disputes, documentation, and rights are treated.
11.4. Pakistan (Sunni-majority; strong registration architecture on paper)23
Pakistan’s Muslim Family Laws Ordinance 1961 (MFLO) emphasises reporting/registration of marriage through a Nikah Registrar mechanism.
Implication for Misyar-like arrangements: Even if a “Misyar-style” understanding (non-cohabiting / waived rights) were privately attempted, the decisive issue becomes registration and enforceability, especially for maintenance claims, dower, and children’s status.
11. 5.Morocco (Maliki tradition; reformist family code approach)24
- Morocco’s Moudawana (Family Code) is often cited for regulating family formation through judicial oversight and structured conditions (notably in polygamy regulation).
- Morocco has also had ongoing reform debates, including reported proposals to strengthen women’s ability to oppose polygamy and enhance protections.
Practical takeaway: Morocco shows how modern Muslim family law can preserve Islamic legitimacy while tightening safeguards through courts, documentation, and conditions reducing the space for “shadow marriages.”
11. 6. Malaysia (Shariah family law system; strong registration emphasis)25
Contemporary Malaysian legal scholarship and statutory compilations highlight mandatory registration under state Islamic family law enactments, reflecting a policy focus on women’s and children’s protection in disputes.
Practical takeaway: Malaysia illustrates a regulatory model where the state treats unregistered marriages as a major vulnerability factor and frames reforms through a maqāṣid-style welfare lens.
11. 7.United Arab Emirates (rapid legal reform; civil family law options for non-Muslims)26
The UAE has introduced and publicised civil marriage frameworks (notably for non-Muslims in certain jurisdictions), with formal procedures for authentication/registration.
Practical takeaway: Although not a “Misyar/Mutʿah” endorsement, UAE reforms show a state strategy: reduce informality through court authentication and documentation.
12. Conclusion
Mutʿah and Misyar, though often discussed together, present fundamentally different legal problems. Mutʿah is, at its core, a sectarian–doctrinal divergence. Twelver Shiaʿi jurisprudence typically treats it as textually anchored in Qur’ān 4:24, reading the verse as authorising a distinct contractual form of marriage. Sunni law, by contrast, regards Mutʿah as prohibited on the basis of Prophetic reports that establish a permanent ban, thereby producing a near-consensus of impermissibility within Sunni Fiqh. The disagreement is thus not peripheral but rooted in competing hermeneutics of scripture, authority, and abrogation. Misyar, however, is primarily a structural and ethical dilemma within Sunni contexts. Many Sunni jurists accept its formal validity where the pillars of Nikah are satisfied, yet simultaneously caution that it may hollow out the social purpose of marriage, particularly when secrecy and the waiver of obligations become the true objective. Egypt’s Dār al-Iftā’ exemplifies this approach by affirming validity where legal conditions are met, while acknowledging the attendant moral and social risks.
The core crisis that emerges across jurisdictions is the widening gap between “validity” and “protection.” The gravest harms arise where marriage is conducted informally or in secrecy, leaving women and children unable to effectively claim fundamental rights, maintenance, dower, documentation of lineage, inheritance where applicable, and custody or support. Comparative experience demonstrates that state enforceability is often more protective than purely private contracting. Frameworks such as Pakistan’s registration regime under the Muslim Family Laws Ordinance, Malaysia’s mandatory registration requirements, and Morocco’s code-based judicial oversight reveal that documentation and public accountability significantly reduce vulnerability and abuse.
A maqāṣid-based evaluation offers the most persuasive bridge across schools of law and across states. Even where jurists differ doctrinally, there is broad convergence on the objectives of Islamic family law: dignity, welfare, protection of lineage, and the prevention of harm. When Mutʿah or Misyar are deployed as instruments of convenience, to evade responsibility, or as commodified forms of “halal dating,” they fail this substantive test, even if their outward form is defensible in juristic terms.
Accordingly, a publication-quality policy framework must reconcile doctrinal diversity with effective rights protection. At a minimum, this requires mandatory registration or legally robust documentation to ensure enforceability; a presumption against secrecy through public acknowledgement or at least verifiable legal notice; informed consent accompanied by written disclosure, particularly where rights are waived; non-waivable protections for children, including support obligations and safeguards against abandonment; clear and accessible legal remedies for maintenance, dower, and proof; and firm anti-exploitation measures regulating intermediaries and platforms that commercialise “marriage-as-a-service.”
Islamic marriage is not merely a contract; it is a moral covenant with social consequences. Where form is preserved but responsibility is engineered away, the law may still recognise a marriage, yet the ethical architecture of Nikah collapses. Comparative evidence suggests that the most effective means of preserving the Qur’anic ideals of tranquility, mercy, and dignity lies not in rhetorical condemnation, but in serious, enforceable regulation, documentation, transparency, and rights protection, so that marriage remains a covenant of care rather than a device of convenience.
Footnotes
- The Qur’an, Surat al-Rūm 30:21.
- Abu Ḥāmid al-Ghazālī, Iḥyāʾ ʿUlūm al-Dīn (Dār al-Maʿrifah 2005) vol 2, bk 12.
- Ziba Mir-Hosseini, Marriage on Trial: Islamic Family Law in Iran and Morocco (I.B. Tauris 2000) 43–47.
- Mohammad Hashim Kamali, Maqasid al-Shariah Made Simple (IIIT 2008).
- Wael B Hallaq, An Introduction to Islamic Law (CUP 2009) 54–55.
- The Qur’an, Surat al-Nisa 4:24.
- Hossein Modarressi, ‘Temporary Marriage in Shiʿi Law’ (1985) 6 Islamic Studies 201.
- MMuhammadibn Ismāʿīl al-Bukhari, Ṣaḥīḥ al-Bukhari (Dār Ṭawq al-Najāḥ) hadith 5115.
- Muslim ibn al-Ḥajjāj, Ṣaḥīḥ Muslim (Dār Iḥyāʾ al-Turāth) hadith 1406.
- Jonathan A C Brown, Hadith: Muhammad’s Legacy in the Medieval and Modern World (Oneworld 2017) 169–172.
- Mir-Hosseini (n 3) 88–92.
- Islam Question & Answer, ‘Misyar Marriage’ https://islamqa.info accessed 10 January 2026.
- Yusuf al-Qaradawi, Fiqh al-Usrah (Wahbah 2001) 214–217.
- Mohammad Fadel, ‘Public Reason as a Strategy for Principled Reconciliation’ (2007) 8 Chicago Journal of International Law 1.
- M K Masud, ‘Common Law Marriage, Zawaj ʿUrfi and Zawaj Misyar’ in Masud, Messick and Powers (eds), Islamic Legal Interpretation (Harvard UP 1996) 259–262.
- International Islamic Fiqh Academy, Resolutions and Recommendations (OIC 2019) res 144 (15/3).
- Kamali (n 4) 75–90.
- Jasser Auda, Maqasid al-Shariah as Philosophy of Islamic Law (IIIT 2008) 125–131.
- Zainab Zulfikar, ‘Fatwa on Misyar Marriage in the View of Yusuf al-Qaradawi’ (2023) 7 Journal of Islamic Law Studies 44.
- See generally Frank E Vogel, ‘Islamic Law and Legal System in Saudi Arabia’ (Brill 2000) Ch. 6; Yusuf al-Qaradawi, Fiqh al-Usrah (Wahbah 2001) 214–217 (on Misyar debates in the Gulf).
- Arab Republic of Egypt, Law No 1 of 2000 on the Organisation of Certain Procedures in Personal Status Matters (Art 17); Dar al-Ifta al-Misriyyah, ‘Ruling on Misyar Marriage’ (Official Fatwa), discussing validity subject to integrals and conditions of nikah.
- Civil Code of Iran 1928 (as amended) arts 1075–1077 (recognising temporary marriage); Ziba Mir-Hosseini, Marriage on Trial: Islamic Family Law in Iran and Morocco (IB Tauris 2000) 43–60.
- Muslim Family Laws Ordinance 1961 (Pakistan) ss 5–6 (registration of marriage; regulation of polygamy); PLD 2010 SC 605 (emphasising statutory architecture of family law rights).
- Kingdom of Morocco, Moudawana (Family Code) 2004 arts 16, 40–46 (documentation and judicial control of marriage and polygamy); Mir-Hosseini (n 3) 121–145.
- Islamic Family Law (Federal Territories) Act 1984 (Malaysia) ss 25–34 (registration and validity); Najibah Mohd Zin and others, Islamic Family Law in Malaysia (Sweet & Maxwell 2016).
- United Arab Emirates, Federal Decree-Law No 41 of 2022 on Civil Personal Status; Abu Dhabi Law No 14 of 2021 on Civil Marriage and Divorce for Non-Muslims (illustrating state policy of documentation and court authentication).