A Comparative Exposition of the Law of Husband and Wife in terms of Islamic Law, South African Law and the Law of England and Wales

The primary concern of this article is a comparative analysis marriage law in three legal systems – namely, Islamic law, South African and English law. similarities differences between these are highlighted. demonstrates that although there the systems, outweigh similarities. This begs question whether (Muslim personal general family particular) can be recognised accommodated implemented (both constitutional democracies) without compromising principles while at same time upholding rights contained Bill Rights. To end, undertaken entails discussion, inter alia, betrothal (engagement), requirements for marriage, as well proprietary consequences applicable