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This study aims to examine the implementation of inheritance law in Islam through a comparative study of inheritance practices in several Muslim countries. This study uses a comparative descriptive method by collecting data through literature study and analysis of relevant literature. Several Muslim countries that are the object of study include Saudi Arabia, Egypt, Indonesia, and Malaysia. These countries were chosen because they represent different Islamic legal traditions and have differences in their inheritance practices. The results of this study indicate that although there are similarities in the principles of inheritance law in Islam, their implementation may differ in each country. Saudi Arabia, as a country that strictly implements Sharia, follows the inheritance system specified in the Al-Qur'an and the hadiths of the Prophet Muhammad. Egypt, on the other hand, has an inheritance system which is influenced by their national laws which sometimes conflict with Islamic principles. Indonesia and Malaysia, which employ mixed legal systems, have inheritance laws that incorporate Islamic principles but also take into account cultural factors and local customs. It is hoped that the results of this research can become the basis for improving and developing inheritance law systems in Muslim countries, so that they can achieve justice in accordance with Islamic principles.
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Pakarti et al. (2023) studied this question.
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