Purpose – In contemporary Muslim societies, Islamic family law plays a central role in shaping the relationships between men and women in marriage, divorce, child custody, inheritance, and broader domestic life. The legal experiences of Indonesia and Morocco, anchored in Sharia principles, illustrate distinct trajectories of reform that respond to growing demands for gender equality. This study examines how Islamic family law frameworks in these two countries interpret and accommodate gender-equitable values within their respective socio-legal contexts. Design/methodology/approach – This research employs a qualitative method based on literature analysis. Primary sources include Indonesia's Marriage Law No. 1 of 1974 and Morocco's 2004 Family Code (Mudawwanah al-Usrah), complemented by scholarly articles and previous research. The data were thematically analyzed to reveal points of convergence and divergence in the articulation and application of gender-inclusive legal norms. Findings – While both legal systems draw from Islamic Sharia foundations and provide formal protections for women and children—such as a woman's right to initiate divorce and the prioritization of the child's welfare in custody decisions—they diverge in their structuring of gender relations. The Moroccan Mudawwanah advances an egalitarian model that recognizes the wife as a legal partner equal to her husband. In contrast, Indonesia's Marriage Law retains a hierarchical model in which the husband is positioned as head of the household, reflecting enduring patriarchal norms. These differences underscore how legal reforms interact with prevailing social and cultural logics. Research implications/limitations – The study offers critical insight into the capacity of Islamic family law to adapt toward greater gender inclusivity. However, its reliance on textual sources limits the scope to normative analysis, suggesting the need for future empirical research to assess how these laws are interpreted and enacted within lived community settings. Originality/value – This study contributes to the discourse on Islamic legal reform by illustrating how gender equality can be negotiated within Sharia-based legal systems. By highlighting the role of cultural context and interpretive flexibility, the research offers a more nuanced understanding of the dynamic relationship between law, gender, and society in the modern Muslim world.
Shiddieqy et al. (2025) studied this question.