This study provided a comparative analysis of the ethical and legislative frameworks governing children’s rights in Islamic Sharia and international law, using the cases of three countries with distinct legal models: Kyrgyzstan, Egypt, and Malaysia. The aim of the research was to identify the systemic gap between normative dec- larations and the practical implementation of child protection in Muslim-majority societies. The study employed a qualitative methodology, including comparative analysis of international conventions, na- tional legislation, doctrinal sources of Islamic law, and reports by international organisations. The find- ings demonstrated that Islamic doctrine – particularly through the prism of the higher objectives of Sha- ria (Maqasid al-Sharia) – offers a strong conceptual foundation for the protection of children’s rights. At the same time, case study analysis revealed that the key obstacles to their realisation are legal pluralism (Kyrgyzstan); jurisdictional conflicts in dual legal systems (Malaysia); and enforcement difficulties even in codified systems (Egypt), especially in the fight against child marriage. Across all cases, the most vulnerable party is the girl child, whose rights to education, health, and free choice are often neglected. It was established that effective child protection requires not a mere replication of international stand- ards, but the development of integrated strategies that harmonise secular legislation with correct inter- pretations of Sharia, engage religious leaders in promoting humanistic interpretations, and aim at trans- forming deeply rooted social attitudes. Research results may be used by legislative bodies to harmonise national laws with international standards, as well as by law enforcement and judicial authorities
Dzhabara et al. (Thu,) studied this question.