Abstract
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.
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