Islamic Adaptations to Western Europe and North America: The Importance of Contrastive Analyses

The article examines the ways Islamic leaders have adapted to conditions in Britain, France, and the United States by taking one problem-how a Muslim woman can obtain a religious divorce-and identifying contrasts across those three countries. It emphasizes two contrasts among the three countries: the degree of residential concentration of Muslims and the social effects such concentration may have, and the legal legitimacy of religion in civil courts. Muslim leaders have crafted institutions accordingly: in Britain, shariah councils emerging from tight-knit communities and regarded by jurists as relatively benign; in France, Islamic leaders constrained to emphasize the Islamic legitimacy of civil institutions; and in the United States, leaders developing contractual instruments in response to relatively favorable judicial reactions.